Colvin + Hallett attorneys provide tax advice and opinions, typically at the request of accountants or lawyers, with respect to the tax consequences of contemplated transactions. Our attorneys have vast experience advising and drafting formal legal opinions, which is informed by our defense of formal opinions in audits, appeals, and litigation. We draw on this experience to meticulously draft opinions able to provide protection from IRS penalties and withstand a challenge. In fact, some of our opinions have been challenged, but to date, none has been defeated.
Advised parties involved in captive insurance arrangements potentially covered by IRS Notice 2016-66 regarding taxpayer and material advisor disclosure obligations, including captive management companies, actuaries, accountants, and lawyers.
Provided opinion regarding whether developers who bought properties and sold them to related LLCs that developed the property were eligible for capital gain treatment.
Offered opinions regarding the proper tax treatment of litigation recoveries and/or lawsuit settlements, including whether damages are included in income or are excludable because they were paid on account of physical personal injury or sickness, and/or whether damages are related to employment or civil rights actions.