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This memo is provided to summarize amended requirements for covered opinion which fully described in sec. 10.35 of Circular 230. The requirements are mandatory and failure to comply with it may result in monetary penalties and other sanctions.
Circular 230 defines covered opinion as written advice (including electronic communications) by a practitioner concerning one or more Federal tax issues arising from (a) listed transactions (b) a plan or arrangement the principle purpose of which is the tax avoidance or (c) a plan or arrangement with a significant purpose of tax avoidance where the written advice is a reliance opinion, a marketed opinion, subject to conditions of confidentiality, or subject to contractual protection...
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This memo is provided to summarize amended requirements for covered opinion which fully described in sec. 10.35 of Circular 230. The requirements are mandatory and failure to comply with it may result in monetary penalties and other sanctions.
Circular 230 defines covered opinion as written advice (including electronic communications) by a practitioner concerning one or more Federal tax issues arising from (a) listed transactions (b) a plan or arrangement the principle purpose of which is the tax avoidance or (c) a plan or arrangement with a significant purpose of tax avoidance where the written advice is a reliance opinion, a marketed opinion, subject to conditions of confidentiality, or subject to contractual protection...
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General points of the essay
Covered Opinion
expert opinion
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