This opinion is not a “will” opinion (the highest standard, typically reserved for straightforward issues without factual risk). There are inherent factual risks (e.g., tenant income recertification errors). However, based on our solid review, those risks are not sufficiently material to disqualify the opinion. V. Reliance This opinion is rendered solely to the addressee in connection with the above-referenced transaction. No other person or entity is entitled to rely upon this opinion without our prior written consent. This opinion speaks only as of the date hereof, and we undertake no obligation to update it for changes in law or fact occurring after this date. VI. Signature Very truly yours,
Federal Income Tax Opinion – Solid Review Project: Riverfront Apartments (LIHTC Transaction) Taxpayer: Riverfront Housing Associates, LP sample tax opinion letter
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). ATTORNEY-CLIENT COMMUNICATION This opinion is not a “will” opinion (the
This is a sample tax opinion letter. This type of letter is typically issued by tax counsel to a lender (or an investor) in a syndicated tax credit transaction (e.g., Low-Income Housing Tax Credits, Historic Tax Credits, or Renewable Energy Tax Credits). This opinion speaks only as of the date
Board of Directors Lender Partners, LLC 123 Finance Way New York, NY 10001
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