Extend your team’s capabilities with focused research, written analysis, and transaction support—built around your client relationship and the issue at hand.
CPAs & EAs · Attorneys · Wealth advisors · Private equity teams
We’ll define the analysis and support needed to move it forward.
We tailor the scope to your facts, goals, and timing. The work may span several of these areas.
Analyze a defined set of facts, applicable authorities, competing interpretations, and implementation considerations. Match the work product to the decision your client needs to make.
What the work can includeA memorandum identifying facts, assumptions, analysis, and conclusions.
Evaluate whether a formal opinion is appropriate. Define the issue, reliance, intended recipients, assumptions, and applicable standard before beginning.
What the work can includeA separately scoped opinion engagement, subject to facts and supporting authorities.
Assess whether ruling guidance is available and useful, develop the factual and technical submission, and coordinate the request with counsel and other advisors.
What the work can includeA feasibility assessment and, if engaged, submission and response support.
Provide a technical resource for structuring, diligence, issue resolution, and complex tax discussions. Identify when legal, valuation, actuarial, or other specialist work is needed.
What the work can includeFocused research, meeting support, or a defined transaction workstream.
Explain fund structures, allocations, distributions, reporting, and tax considerations in language suited to investors and investment teams.
What the work can includeA tailored presentation, workshop, or investor tax education briefing.
Deliverables are agreed in advance and shaped around the decision you need to make.
We can structure the engagement around your working relationship. Client consent, confidentiality, conflicts, and permitted use of work product are addressed in the engagement process.
No. The IRS has procedural requirements and areas in which it will not issue rulings. Feasibility, fees, timing, and taxpayer-specific reliance need assessment.
No. A formal opinion requires a separately defined engagement and analysis of the relevant facts and authorities.
No. Counsel should determine whether and how an engagement should be structured for a particular matter.
Tell us what you’re considering, what’s at stake, and when you need to act.