We provide opinion letters on the reasonableness of compensation paid to executives and other key employees at hospitals and other tax-exempt organizations subject to the excess benefit transactions rules of Internal Revenue Code section 4958.
We also provide opinion letters to companies subject to FIN 48. FASB does not require an opinion letter to show that the more-likely-than-not standard has been met. However, FASB believes that an opinion letter can be valuable support and that management should decide whether to obtain an opinion letter after evaluating all available evidence and the statutory and case law.
Complex facts and the subjective nature of compensation may lead many companies to obtain tax opinion letters to protect themselves (when the amount at issue is significant).
We also provide opinion letters to preparers of business valuations, when compensation paid to owners and/or their family members must be normalized.