Understanding General Counsel's Memorandum [Tax Law] and Its Importance
Definition & meaning
A general counsel's memorandum is a document created by the chief counsel of the Internal Revenue Service (IRS). This memorandum outlines the legal considerations surrounding specific tax issues and reflects the IRS's stance on various revenue rulings. While it is not an official legal document and does not carry the weight of law, it is considered an important informal opinion that can guide IRS officials and taxpayers on tax matters.
Legal use & context
General counsel's memorandums are primarily used within the realm of tax law. They serve as a reference for IRS officials when making decisions on tax-related issues. Tax professionals and attorneys may also refer to these memorandums to understand the IRS's position on specific tax matters. Users can manage some tax issues independently using legal templates from US Legal Forms, which are designed to assist with common tax-related procedures.
Real-world examples
Here are a couple of examples of abatement:
Example 1: A general counsel's memorandum may address the tax implications of a new tax credit, guiding IRS officials on how to apply it in revenue rulings.
Example 2: A memorandum could clarify the IRS's stance on the deductibility of certain business expenses, helping taxpayers understand their rights and obligations (hypothetical example).