Webinars On-Demand

Tax Opinion Writing Workshop (Theory)

Overview    

Drafting a technically accurate, legally sound and professionally structured tax opinion is a critical skill for today's tax practitioners and advisors. As South African tax legislation grows more intricate and SARS intensifies its audit scrutiny, taxpayers require strategic, evidence-based guidance. Providing high-value transactional advice demands that practitioners conduct exhaustive legal research, analyse complex statutory provisions, and articulate defensible conclusions with absolute clarity. 

A poorly formulated or poorly researched tax opinion exposes the practitioner to substantial professional indemnity risks and leaves clients vulnerable to severe tax penalties and interest. Tax advisors must know how to construct opinions that serve as reliable shields during disputes or audits. This requires a systematic understanding of the hierarchy of tax law, proper evidentiary weighting of legal authorities, and the practical distinction between standard tax advice, a "more-likely-than-not" opinion, and an expert opinion. 

Join Adv. Christel van Wyk as she conducts this practical, interactive workshop on tax opinion writing. Designed specifically for legal and tax professionals, this session unpacks the essential mechanics of researching, structuring, and writing defensible tax opinions that comply with legal, ethical and professional standards.  

Learning objectives   

Attending this webinar will equip you with the following skills:  

• Understand the key elements and structural framework of a professionally drafted tax opinion. 

• Conduct targeted and authoritative tax research using recognised methodologies. 

• Distinguish between primary and secondary sources of tax law and evaluate their evidentiary value. 

• Prepare both a more-likely-than-not opinion and an expert tax opinion based on relevant legal authority. 

• Strengthen written communication skills to deliver clear, practical and client-focused tax advice. 

Content   

The webinar will cover the following topics: 

• Part 1: Introduction to Tax Opinion Writing  

  • Purpose and role of tax opinions  

  • Professional responsibilities of the tax advisor  

  • Characteristics of an effective tax opinion  

• Part 2: Key Elements of a Tax Opinion  

  • Structuring a tax opinion  

  • Identifying material facts  

  • Legal analysis and application  

  • Developing reasoned conclusions  

  • Professional presentation and formatting  

• Part 3: Tax Research Methodologies and Sources  

  • Tax research methodologies  

  • Primary sources of tax law  

  • Secondary sources of tax law  

  • Legislative interpretation  

  • Evaluating legal authority  

• Part 4: Specific Tax Opinion Topics  

  • More-likely-than-not opinions  

  • Expert tax opinions  

  • Risk assessment and defensible conclusions  

• Part 5: Practical Examples  

  • Practical drafting exercises  

  • Case-based examples  

  • Common drafting errors and best practices  

  • Client-focused communication techniques