Legal Opinions and Tax Planning Memos

Legal opinions are a valuable tool for addressing complex tax questions and ensuring that your intended tax results are actually achieved. As Toronto tax lawyers, we prepare detailed legal opinions to help clients proceed confidently, reduce risk, and withstand CRA scrutiny.

Some tax issues require a detailed review of current legislation, case law, CRA policy, and even proposed legislation. A formal legal opinion helps you proceed with confidence especially when a decision could result in significant tax exposure.

In more complex situations, especially where a transaction is being planned, we may also prepare a step memo. Step memos outline a sequence of steps required to achieve a desired tax result and help avoid unintended consequences such as a denial of exemptions or a reassessment by the CRA.

Examples of Legal Opinions and Memos

We have experience preparing legal opinions and step memos on a wide range of tax issues. As Toronto-based tax lawyers, we tailor each opinion to the specific facts, legal risks, and intended outcomes involved. Examples include:

• Whether gambling income is taxable;
• Whether insurance proceeds are taxable;
• CRA advanced ruling requests;
• Steps to ensure entitlement to the lifetime capital gains exemption;
• Structuring share purchases and sales for favourable tax treatment;
• How to achieve RRSP or TFSA eligibility for certain investments;
• How to avoid or defer taxation, where possible;
• Tax consequences of proposed transactions;
• Tax consequences of separation or divorce; and

• Many more.

Why Work with Kirshen Tax Law?

You’ll work directly with a Toronto tax lawyer who understands how to align legal analysis with practical, CRA-compliant outcomes.

Book a Free Consultation

If you need a tax opinion or step memo, contact us today for a free consultation. A Toronto tax lawyer at Kirshen Tax Law will walk you through your options and help you plan with confidence.