Claude Skills by sunyifeisb-art

A post-restructuring tax compliance memorandum must identify the filing obligations and substantive tax risks created by the transaction, explain the compliance consequence of non-performance for each, and provide a specific recommended action — not merely catalog what documentation should exist.

A Tax Court petition must satisfy the formal requirements of the applicable Tax Court rules and should challenge each adjustment in the notice of deficiency with a separately labeled assignment of error, without omitting any adjustment that needs to be preserved for litigation.

A buy-side tax due diligence report should identify and quantify tax exposures across a low-to-high range, analyze relevant loss-attribute limitations and related tax attributes, and recommend transaction protections for each material exposure.

A federal income tax opinion letter on a spin-off transaction should analyze the statutory and regulatory requirements for a tax-free reorganization and distribution with multi-factor reasoning and factual support, and should address the principal requirements in separate sections with appropriate opinion qualification language.

A tax structure memorandum for a private equity acquisition of an S-corporation target should compare structural alternatives with per-seller after-tax computations and address election mechanics for a deemed asset sale, inventory-method recapture, the business interest limitation under current and prospective adjusted taxable income definitions, and related basis and depreciation issues.

A transfer pricing documentation review memorandum must assess a multinational documentation package against the applicable transfer pricing documentation framework, analyze entity substance and DEMPE functions, identify local compliance deadlines as urgent action items, and produce both a risk quantification table and an action item matrix.

Extracting assessed items from a state tax authority notice requires separately cataloging each tax type and each component deficiency, identifying the challenge issues applicable to each line item, and flagging procedural vulnerabilities — not just reading the total deficiency from the cover page.

Consolidating document requests from multiple tax-authority summonses requires assigning a response recommendation to every request, such as produce, withhold with privilege log entry, or narrow, and identifying any summons that warrants a challenge based on the governing summons-enforcement framework.

Extracting key terms from intercompany agreements requires populating structured tables for each agreement type and flagging issues such as auto-renewals at stale pricing, percentage inconsistencies across related documents, missing benchmarking support, and deadlines that affect the timing of the response.

Extracting tax attributes from audited financial statements requires cross-checking each attribute across the available disclosure sources because inconsistencies between sources can be material due diligence findings.

Reviewing a draft annual tax compliance report requires checking the arithmetic and legal basis for each material computation, verifying the applicable tax rules for the relevant period, and quantifying any discrepancies identified.

Identifying issues in a notice of deficiency requires checking the notice for arithmetic consistency, analyzing each adjustment issue by issue, and organizing the analysis so that procedural deadlines, litigation posture, and overall exposure are addressed in a clear memorandum.

Reviewing a section 409A valuation report requires assessing each methodological choice for its effect on the concluded common stock value, organizing issues by severity, and evaluating whether the analysis supports the relevant valuation safe-harbor framework.

Reviewing a nonprofit tax exemption application package requires identifying issues that may cause denial, delay, or a request for additional information; prioritizing those that should be corrected before filing; and providing concrete, procedural next steps rather than only noting potential problems.

Identifying weaknesses in a government opposition brief requires locating the specific passage where each error or vulnerability appears, assigning a severity rating, and analyzing the government's silence on arguments the taxpayer raised — not just cataloging the brief's positions.

Analyzing a government summary judgment brief requires verifying the internal consistency of any stated deficiency computation, assessing whether the brief addresses the relevant economic substance analysis under both prongs of the applicable doctrine, and identifying whether any factual contradictions within the brief have implications on more than one issue.

Reviewing a draft IRS closing agreement for issues requires independently verifying computed amounts for directional and arithmetic correctness, assessing structural deficiencies such as missing treaty-relief protection, signing authority, and non-precedential language, and identifying any state tax reporting obligations triggered by the settlement.

A transfer pricing documentation issue-identification memorandum should methodically identify gaps, explain why each gap matters, and outline the follow-up steps needed to remediate the record. Incomplete documentation should be analyzed by specifying what is missing, why it is insufficient, and how the deficiency should be addressed.

Reviewing a tax transaction structure memorandum for a § 338(h)(10) deal requires independently verifying the aggregate deemed sale price computation against the applicable regulatory formula, identifying structural issues that could affect the election, and flagging state conformity risks by jurisdiction.

Redline analysis of an opposing party's parenting plan markup requires systematic change-tracking against a client's original proposal, mediation summaries, and court-ordered temporary orders to surface substantive and procedural risks.

Redline review of a counterparty's postnuptial agreement markup requires change-tracking against the client's original draft and financial disclosures to surface asymmetric provisions, financial quantification, and cumulative enforceability risk.

Redline analysis of a counterparty's prenuptial agreement markup requires systematic tracking of every change against the client's original draft and financial disclosures, with attention to asymmetric provisions, cross-provision interactions, and enforceability risks.

Comparing charitable remainder trust structures against client goals requires applying the relevant tax qualification rules, deduction limitation arithmetic, and identifying potentially disqualifying provisions in draft instruments before a recommendation can be made.

Reconciling creditor claims against estate assets requires applying the governing probate priority framework, separating secured and unsecured components of each claim, and distinguishing allowable claims from those that are legally defective or inadequately documented.

Comparing an estate plan against current federal tax exemption schedules requires evaluating ambiguous formula clauses under plausible interpretations, checking portability and related exclusion history, identifying estate inclusion issues, and assessing whether older documents still operate as intended under current law.

Comparing a proposed final divorce decree against a mediated settlement agreement requires clause-by-clause comparison to identify deviations, assign severity, and assess whether the discrepancies suggest a directional pattern favoring one side.

Comparing a sworn financial declaration against multiple years of tax returns requires source-by-source income reconciliation, correction of improper expense deductions in rental income calculations, and assessment of the legal consequences of material misstatements in sworn filings.

Reviewing a filed gift tax return against the transaction ledger and supporting documents requires reconciling all transfers, verifying annual exclusion qualification conditions, distinguishing direct-payment exclusions from ordinary exclusion gifts, and tracing any election-driven filing obligations.

A compliance gap analysis of a proposed parenting plan against governing statutory requirements demands provision-by-provision mapping against the applicable checklist, support-calculation analysis under the governing state model, and client-specific risk statements for each identified gap.

Comparing a settlement proposal against temporary orders and financial records requires identifying the relevant estate, measuring each party’s proposed allocation against the applicable division benchmark, and flagging missing structural provisions that may create enforcement or implementation risk.

A trust distribution compliance review requires reading the governing instrument against every ledger entry, confirming required co-trustee execution, verifying loan authority and repayment terms, and assessing whether any charitable distribution limits were respected in each period.

Comparing trust draft documents against client instructions requires provision-by-provision deviation analysis that traces the practical downstream consequences of each departure and explains the drafting decisions behind any intentional divergence.

Drafting a stepparent adoption petition requires assembling the required party information and court-filing allegations, addressing any consent revocation period, any pre-adoption support arrears, applicable interstate-placement considerations, and any home study preparer credentials in a companion attorney cover memo.

Drafting an advance health care directive for a client with diminishing capacity requires reconciling potentially inconsistent agent designations across source materials, translating abstract treatment preferences into actionable clinical standards, and addressing companion document requirements and professional responsibility concerns.

Drafting a charitable lead annuity trust requires analyzing the annuity structure against the applicable valuation rate, addressing special-needs beneficiary planning, evaluating private foundation self-dealing constraints, considering transfer-tax consequences for skip-person remaindermen, and handling substitution power limitations.

Drafting a charitable remainder unitrust agreement with mixed-asset funding and joint-life income beneficiaries requires the lesser-of/makeup-account mechanics under the applicable charitable remainder trust rules, precise flip-trigger language under the governing regulations, private-foundation excise-tax analysis as extended to charitable remainder trusts, and a qualified appraisal assessment for non-cash contributions.

Completing a state child support guideline worksheet requires checking income figures against source financial records rather than relying solely on self-reported statements, applying income imputation where a parent is voluntarily underemployed, correcting improper deductions from rental income, and averaging variable compensation over an appropriate multi-year period.

Drafting a consent to adoption in a Maryland independent adoption requires careful attention to revocation timing, paternity status, notice obligations, naming consistency, execution formalities, and related family-support issues.

Drafting a durable power of attorney for an elderly principal with multi-state assets requires curing prior power-of-attorney deficiencies, updating outdated template provisions, including authority for benefits-preserving trust contributions where needed, addressing multi-jurisdiction recognition, and coordinating health-information authorization.

Drafting a first and final judicial accounting for a surrogate’s court submission requires reconciling the fiduciary’s summary against underlying financial records, classifying receipts and disbursements into the proper accounting schedules, computing any fiduciary compensation under the applicable statutory framework, and explaining investment performance and distribution calculations in a manner consistent with the governing estate administration rules.

Drafting a court-ready estate inventory and appraisal requires correct probate versus non-probate classification, item-by-item listing of securities, art, firearms, and jewelry, appraiser certification, and an issues memo flagging business-entity transfer restrictions and valuation documentation gaps.

A gift and estate tax planning memorandum for a high-net-worth client requires analyzing federal and state transfer-tax exposure, reviewing life-insurance ownership and transfer risks, assessing withdrawal-right mechanics for trust gifts, and evaluating timing-sensitive lifetime-giving strategies under any applicable exclusion regime.

Drafting a grantor retained annuity trust agreement for privately held shares requires identifying the applicable transfer and valuation mechanics, checking any ownership-transfer restrictions in the governing company documents, confirming trustee independence and authority, and flagging valuation and mortality considerations in the issues memo.

Drafting an irrevocable life-insurance trust for a blended family requires structuring withdrawal rights for beneficiaries, addressing transfer and ownership issues for any policy insuring the grantor, coordinating transfer-skipping transfer tax planning for skip-person beneficiaries, and aligning the draft with the broader estate plan in a companion cover memo.

Drafting a last will and testament for a client with complex family dynamics requires integrating retirement-benefit designation issues, inherited-account distribution rules, special-needs planning, executor conflict analysis, closely held business transfer restrictions, and digital-asset access instructions into a companion drafting memorandum.

Drafting a marital settlement agreement from a mediated term sheet requires reconciling inconsistencies across supporting financial information, valuation materials, and account records, while addressing the substantive terms of property division, support, custody, taxes, enforcement mechanisms, and any companion issues memorandum in an integrated agreement.

Producing a redline markup of an opposing party's proposed parenting plan requires advancing the client's position through targeted revisions with embedded commentary, correcting any misstated modification standard, and addressing child-specific educational accommodations and transportation burden with the applicable governing authority.

Producing an article-by-article redline markup of a proposed postnuptial agreement requires identifying provisions that are asymmetric, undisclosed, or potentially unconscionable, and replacing them with client-protective language accompanied by explanatory commentary.

Producing a prioritized redline markup of a draft prenuptial agreement requires identifying asymmetric and over-broad provisions unfavorable to the client, supplying replacement contract language, and embedding commentary explaining the legal basis and strategic rationale for each change.

Produce a redline markup of an opposing proposed marital settlement agreement with marginal commentary. Focus on contract-ready replacement language, issue spotting against supporting financial and parenting materials, and a priority-ordered cover memo that frames the negotiation posture in procedural terms.