Tax Opinion / Penalty Protection Consultation
$999.00
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Businesses, business owners, advisors, and tax professionals often need legal analysis before taking a tax return position, reporting a transaction, claiming a deduction or credit, or advising a client on a position that may later be reviewed by the IRS or a state tax agency. The Tax Opinion / Penalty Protection Consultation is designed to help identify the legal authorities, factual assumptions, reporting risks, and penalty considerations that should be evaluated before a position is taken.
This package is appropriate when a taxpayer, CPA, attorney, or business advisor needs an initial legal review of a proposed tax position, transaction, reporting approach, or compliance issue. The consultation is intended to determine whether there is meaningful legal support for the position, whether additional factual development is needed, and whether a formal written tax opinion or penalty-protection memorandum may be appropriate.
The review may include an initial assessment of relevant statutes, regulations, IRS guidance, case law, administrative authority, reporting requirements, disclosure considerations, and potential accuracy-related penalty exposure. The goal is to help the client understand the strength of the position, the likely areas of IRS or state tax scrutiny, and the steps that may reduce penalty risk if the position is later challenged.
This package does not include a formal written tax opinion unless separately agreed in writing. If a formal opinion is warranted, The Karam Firm can provide a separate engagement proposal based on the complexity of the issue, the applicable authorities, the number of entities or tax years involved, and the level of opinion required.
Includes: up to 2 attorney hours, review of one defined tax issue, review of up to 50 pages of materials, identification of relevant authorities, one strategy call, and a written summary of preliminary conclusions and recommended next steps.
Additional work may be required for: formal written tax opinions, substantial legal research, multi-entity or multi-year issues, transaction document review, additional fact finding and client questions, return disclosure analysis, privilege-sensitive investigations, or communications with tax agencies.
Flat-rate packages are available for defined-scope matters only. Fees may vary based on complexity, number of tax years, number of entities, urgency, document volume, and whether additional representation is required. A flat-rate package does not include court appearances, audit representation, appeals representation, litigation, or negotiations with tax agencies unless expressly stated in a written engagement agreement.
Businesses, business owners, advisors, and tax professionals often need legal analysis before taking a tax return position, reporting a transaction, claiming a deduction or credit, or advising a client on a position that may later be reviewed by the IRS or a state tax agency. The Tax Opinion / Penalty Protection Consultation is designed to help identify the legal authorities, factual assumptions, reporting risks, and penalty considerations that should be evaluated before a position is taken.
This package is appropriate when a taxpayer, CPA, attorney, or business advisor needs an initial legal review of a proposed tax position, transaction, reporting approach, or compliance issue. The consultation is intended to determine whether there is meaningful legal support for the position, whether additional factual development is needed, and whether a formal written tax opinion or penalty-protection memorandum may be appropriate.
The review may include an initial assessment of relevant statutes, regulations, IRS guidance, case law, administrative authority, reporting requirements, disclosure considerations, and potential accuracy-related penalty exposure. The goal is to help the client understand the strength of the position, the likely areas of IRS or state tax scrutiny, and the steps that may reduce penalty risk if the position is later challenged.
This package does not include a formal written tax opinion unless separately agreed in writing. If a formal opinion is warranted, The Karam Firm can provide a separate engagement proposal based on the complexity of the issue, the applicable authorities, the number of entities or tax years involved, and the level of opinion required.
Includes: up to 2 attorney hours, review of one defined tax issue, review of up to 50 pages of materials, identification of relevant authorities, one strategy call, and a written summary of preliminary conclusions and recommended next steps.
Additional work may be required for: formal written tax opinions, substantial legal research, multi-entity or multi-year issues, transaction document review, additional fact finding and client questions, return disclosure analysis, privilege-sensitive investigations, or communications with tax agencies.
Flat-rate packages are available for defined-scope matters only. Fees may vary based on complexity, number of tax years, number of entities, urgency, document volume, and whether additional representation is required. A flat-rate package does not include court appearances, audit representation, appeals representation, litigation, or negotiations with tax agencies unless expressly stated in a written engagement agreement.