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Tax and crypto glossary
Plain-English definitions of the terms that show up in IRS letters, crypto tax reports, offshore disclosures, and opinion letters, written by the attorneys and accountants who deal with them every day. Each term links to the guide or service page where we go deeper.
Browse by topic: All terms Business and Corporate (18) Crypto Tax (71) International Tax (24) IRS Forms (47) IRS Notices and Letters (10) Opinion Letters (4) Tax Controversy (68) Web3 Regulation (7)
Showing 4 terms in Opinion Letters.
A
- Attorney-client privilege (tax)
- Attorney-client privilege protects confidential communications between a client and attorney made to obtain legal advice, and it is the reason taxpayers with potential exposure should speak to a tax attorney before an accountant.
K
- Kovel agreement
- A Kovel agreement is an arrangement in which an attorney engages an accountant to assist in providing legal advice, extending attorney-client privilege to the accountant's work on that matter.
M
- More likely than not
- More likely than not is a confidence level in a tax opinion meaning the attorney concludes there is a greater than 50 percent chance the position would be upheld if challenged.
O
- Opinion letter
- An opinion letter is a signed written analysis from an attorney that applies the law to a client's specific facts and states a conclusion at a defined level of confidence, used to support a position with a preparer, a counterparty, or the IRS.
