Sample Tax Opinion Letter Access

[Date]

The purpose is to confirm that, in the opinion of counsel, the tax benefits will be available, but it carries the caveat that the opinion is based on a "solid review" of facts and law (i.e., more rigorous than a "standard" review but short of a "should" or "will" opinion under tax shelter rules). sample tax opinion letter

Our opinion is subject to the following assumptions: [Date] The purpose is to confirm that, in

: The heart of the document, where the professional applies the Internal Revenue Code (IRC) , Treasury regulations, and relevant case law to the facts. Conclusion (The Opinion) : A brief introduction identifying the scope, the

It is more likely than not that the Project will generate the projected annual tax credit amount of approximately $1,200,000 (based on the eligible basis certified by the HFA), provided that the applicable fraction (the ratio of low-income units to total units) remains at or above the minimum required percentage.

: A brief introduction identifying the scope, the parties involved, and the specific legal questions posed. Statement of Facts