E-Verify Mandated for All Federal Contractors Starting Sept 8
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CONFIDENTIAL: ATTORNEY-CLIENT PRIVILEDGED; ATTORNEY WORK PRODUCT: Emails and attachments received from us may be protected by the attorney-client privilege, as attorney work-product or by virtue of other privileges or provisions of law. If you are not an intended recipient, please do not read, copy, use, forward, or disclose any such communications or attachments to others; immediately notify the sender by reply email; and delete the email and the reply from your system. Any unauthorized disclosure, copying, distribution, or use of emails from us or any attachments thereto is prohibited.
UNITED STATES INTERNAL REVENUE SERVICE (IRS) CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS in Circular 230, we inform you that, unless and to the extent we otherwise state, any federal tax advice contained in communications from us (including any attachments) is not intended or written to be used, and cannot be used, by any taxpayer for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another person any transaction or matter addressed therein.
Circular 230 Explanation
Effective on June 21, 2005, all tax practitioners, including lawyers and certified public accountants, must follow certain rules (Circular 230) when providing written statements about federal tax issues. The scope of those rules is extremely broad. The rules apply whenever attorneys and other tax professionals provide written advice about a transaction that has a material degree of tax motivation. Taxpayers may rely on such advice for protection from Internal Revenue Service penalties only if the advice is provided in the form of a "covered opinion," which must comply with complex requirements.
In many cases, our clients seek advice which has tax implications even when they do not intend to utilize our communication for the avoidance of tax penalties. In those cases, rather than undergoing the time and expense of providing advice in the form of a covered opinion, we include the disclaimer above.
There may, of course, be situations where a client will, despite the additional effort and expense involved, request that we issue a covered opinion regarding Federal tax issues. Before preparing such an opinion, the attorney involved will discuss with the client the requirements that must be met, whether it is possible to meet those requirements under the circumstances, and the anticipated time that will have to be spent to meet the stringent covered opinion requirements. However, unless a client instructs us in writing that a reliance opinion is requested, or we conclude after discussion with a client that a reliance opinion is required, the disclaimer above will apply to all written Federal tax advice provided by the Firm.
The presence of the disclaimer does not change the high degree of care and attention that we devote to our tax advice. Moreover, the inclusion of the disclaimer does not indicate that penalties could be imposed on the transaction at issue, but rather merely indicates that the advice we have provided you in such communication does not preclude the IRS from asserting penalties. Finally, please be assured that the use of such a disclaimer to avoid unnecessary legal expenses is similar to the approach adopted by most other tax practitioners.
No assurance of the completeness, comprehensiveness, correctness, or currency of the information included in this website is given. The materials and information presented in this website are not legal advice and should not be relied upon or construed as legal advice. Any views or opinions expressed do not necessarily reflect the view or opinion of the Firm, its attorneys, or its clients. The information provided in this website does not create an attorney-client relationship.
The Firm realizes that the information provided in this website might be considered to constitute advertising in some jurisdictions. The hiring of an attorney is an important decision that should not be based solely upon the information provided in this website regarding the experience and qualifications of the Firm's attorneys. The Firm does not intend or desire to represent any client based upon their review of any portion of this website that does not comply with the legal or ethical requirements for that client's jurisdiction.
Links to other resources on the Internet are provided as citations and aids to help you identify and locate other Internet resources that may be of interest, and are not intended to state or imply that the Firm or any of its attorneys is affiliated or associated with, or is legally authorized to use any trade name, registered trademark, logo, legal or official seal, or copyrighted symbol that may be reflected in the links.
To the extent that the designation of a principal office and/or a responsible attorney with respect to this website is required, the Firm designates its Montgomery, Alabama, USA office as its principal office and designates William D. Coleman as its responsible attorney.
No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers.
The following disclaimer is required by members of the State Capital Group: Member law firms practice independently and not in a relationship for the joint practice of law.