Legal Definitions - General Counsel's Memorandum

A General Counsel's Memorandum is a written document that discusses a legal issue related to tax law. It is issued by the office of the Chief Counsel of the Internal Revenue Service (IRS). The memorandum provides an explanation of the IRS's position on a particular issue and can be used as guidance for taxpayers and tax professionals.

Example 1: The IRS issues a General Counsel's Memorandum discussing the tax implications of cryptocurrency transactions. The memorandum provides guidance on how taxpayers should report their cryptocurrency transactions on their tax returns.

Example 2: The IRS issues a General Counsel's Memorandum explaining its position on a revenue ruling related to the tax treatment of a specific type of investment. The memorandum provides additional clarification and guidance on how the ruling should be applied.

These examples illustrate how a General Counsel's Memorandum can provide guidance and clarification on complex tax issues. The memorandum can help taxpayers and tax professionals understand the IRS's position on a particular issue and ensure that they are complying with tax laws and regulations.