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What is a tax status letter? A tax status letter provides details regarding liabilities, credits, or other outstanding issues for a specific taxpayer. This letter is not a verification of correct reporting.
A tax opinion letter can help in reducing the likelihood of an audit and provide a strong rationale for a tax position or a strategy to minimize your tax exposure by referring to specific IRS codes and rulings.
Both substantial authority and reasonable basis are essentially defined as a conceptual level of confidence; that is, as a determined weight of authorities that support the desired tax treatment of the facts of the situation, out of the total weight of authorities that address the facts of the situation (Regs. Secs.
A tax opinion must conform to one of the following levels of confidence: Not frivolous = There's a 10% to 20% chance your argument will prevail. Reasonable Basis = There's a roughly 20% or 25% chance you'll win. Substantial Authority = There are cases both ways, but there's probably about a 40% chance you'll win.
Debt-For-Tax Opinion means an Opinion of Counsel, of nationally recognized tax counsel, delivered to the Depositor and the Indenture Trustee stating that the Notes specified therein will be debt for United States federal income tax purposes.