Commentary

In cases in which no U.S. tax opinion is provided by the company, or if the tax opinion provided is ambiguous or incomplete, Capital Changes will often research vital facts and relevant Internal Revenue Code provisions and provide guidance to its subscribers in the form of Commentary. Capital Changes does not provide tax advice. Due to the nature of the transaction or the availability of information, Capital Changes is not able to provide Commentary on every transaction. Capital Changes understands that its customers need to book every transaction, whether or not the company provides a tax opinion. Our Commentary helps them do that.

Tax Comments - Comments are included when a company's tax opinion omits a basic, well-settled principle of tax law that subscribers need to remember when booking a transaction or calculating their basis or gain/loss. A Comment may also highlight and explain portions of a company's tax opinion that needs to be emphasized.

Tax Caution - Capital Changes alerts its subscribers of potential adverse tax consequences that may arise in a particular transaction.

Capital Changes' methodology strictly follows the U.S. Internal Revenue Code.