Clio Work for Tax Law
Pick a task, copy the prompt, and run it on your matter in Clio Work.
Prompts
Legal Research
Check the tax effects of converting a C corp to an S corp
Transactional
What are the tax implications of converting a C corporation to an S corporation? Explain the built-in gains tax and recognition period, state conformity issues, estimated tax obligations, and other planning considerations, and cite the controlling Code sections.
Summarize gift and estate tax exemptions
Transactional
What are the current federal estate and gift tax rules, including the annual exclusion, lifetime exemption, and portability? Explain any scheduled changes to the exemption amount and how they affect planning, and cite the controlling Code sections.
Confirm the requirements for a tax-free reorganization
Transactional
What continuity of interest and continuity of business enterprise requirements must a corporate merger meet to qualify as a tax-free reorganization under IRC Section 368? Explain how each test is measured and cite the controlling regulations and cases.
Check the burden of proof in a Tax Court deficiency case
Litigation
What standard of review does the Tax Court apply to an IRS notice of deficiency, and when does the burden of proof shift to the IRS under IRC Section 7491? Explain the taxpayer's requirements for shifting the burden and cite the leading cases.
See how courts apply the economic substance doctrine
Litigation
How have courts applied the two-prong economic substance doctrine under IRC Section 7701(o) to tax shelter transactions? Explain the objective and subjective tests, how penalties apply, and summarize the key cases.
Check how courts treat valuation discounts
Litigation
How do the Tax Court and other courts treat lack of marketability and minority interest discounts when valuing closely held businesses for estate and gift tax? Explain typical discount ranges, what evidence supports them, and summarize the key cases.
Document Analysis
Review an operating agreement's tax provisions
Transactional
Review this partnership or LLC operating agreement for tax classification elections, special allocations, and disguised sale or guaranteed payment risks under Subchapter K. Provide a table with the provision, tax issue, risk level, and recommended revision.
Pull income items and audit flags from returns
Transactional
From these tax returns and financial statements, extract the income items, deductions, credits, carryforwards, and potential audit flags. Provide a table by tax year with source references.
Flag tax exposure in transaction documents
Transactional
Review the transaction documents in this matter and flag any tax exposure or structuring concerns. Provide a table with the issue, source document, potential tax impact, and recommended alternative structure.
Break down an IRS Notice of Deficiency
Litigation
From this IRS notice of deficiency or Tax Court petition, extract the deficiency amounts, asserted penalties, tax years at issue, and statutory bases. Provide the results as a table with key deadlines noted.
Summarize a Tax Court transcript
Litigation
Summarize the factual stipulations, credibility findings, and key legal issues in this Tax Court trial transcript or IRS Appeals conference record. Provide page references for each item and flag issues worth raising on appeal.
Summarize each proposed adjustment
Litigation
From each item in this notice of deficiency, extract the tax year, type of adjustment, amount at issue, the IRS's legal basis, and the taxpayer's response. Provide a table with one row per adjustment.
Skills
Skills save the way your firm does a task, so anyone at your firm gets the same result.
Get consistent, high-quality work from everyone at your firm, every time. A skill saves a task you repeat in your firm’s format and standards, so anyone on your team can run it. Use skills for document analyses, client letters, and strategy recommendations.
Respond to an IRS or state tax notice
Drafts a response to an IRS or state tax notice in the firm's format.
Create This Skill
Create a skill that reads an IRS or state tax notice and drafts a response letter covering the tax year, the proposed adjustment, the client's position, supporting documents in this matter, and the response deadline. It should use my firm's prior response letters as the format.
Build a table of figures across tax years
Extracts key figures from returns and financials into one table across tax years.
Create This Skill
Create a skill that extracts income items, deductions, credits, carryforwards, and potential audit flags from the tax returns and financial statements in this matter into one table. It should compare figures across years and flag large changes.
Draft an entity selection memo
Drafts a client memo comparing entity choices and their tax treatment.
Create This Skill
Create a skill that drafts a client memo comparing entity choices for a new or restructuring business. It should cover federal and state tax treatment, self-employment tax, owner compensation, and conversion considerations, using the facts in this matter and my firm's memo format.
Check tax provisions in an operating agreement
Checks the tax provisions in partnership and LLC agreements against the firm's standard positions.
Create This Skill
Create a review skill for partnership and LLC operating agreements that checks the tax distribution, allocation, partnership representative, and tax classification provisions against my firm's preferred, acceptable, and unacceptable positions, and suggests fallback language.
Track tax controversy deadlines
Calendars every response, petition, and limitations deadline from IRS notices and Tax Court filings.
Create This Skill
Create a skill that reads the IRS notices and Tax Court filings in this matter, identifies every response, petition, and statute of limitations deadline, and adds each one to the matter calendar. It should also create a prep task 14 days before each due date.
Draft Templates
Draft documents from a prompt, or fill your firm’s own templates with details from the matter.
Get from a blank page to a first draft in minutes. Describe the document, and Clio Work drafts it from your matter’s facts and your jurisdiction’s law. Or turn your firm’s own documents into templates that fill in party names, dates, and terms from the matter.
Draft from a prompt
Draft an IRS Appeals protest letter
Transactional
Draft an IRS Appeals protest letter responding to each proposed deficiency adjustment. For each adjustment, state the taxpayer's position, the supporting legal authority, and the documents that support it, and include all required protest elements.
Draft a brief defending a sale-leaseback's economic substance
Litigation
Draft a brief arguing that the client's sale-leaseback had real economic substance and a substantial non-tax business purpose, in response to the IRS's attempt to disallow the resulting tax loss under IRC Section 7701(o). Address both prongs of the test and cite the controlling cases.
Build your firm templates
Tax Engagement Letter
Fills the firm's engagement letter with tax years and services. Upload your firm's version, and Clio Work turns the client name, tax years, services, and fee into fields it fills from each matter. Then review the suggested rule that adds the IRS representation paragraph only when the engagement includes audit or collection representation.
IRS Protest Letter
Starts each appeal of proposed adjustments from the firm's standard protest. Upload your firm's version, and Clio Work turns the taxpayer, tax years, notice date, and proposed adjustments into fields it fills from each matter. Then review the suggested rule that switches between a formal written protest and a small case request based on whether the amount in dispute is over $25,000.
Penalty Abatement Request
Requests relief from IRS penalties in a consistent format. Upload your firm's version, and Clio Work turns the taxpayer, tax period, penalty type, and amount into fields it fills from each matter. Then review the suggested rule that adds the first-time abatement paragraph only when the taxpayer had no penalties in the prior three years.
Visualizations
Visualizations make charts, calendars, and diagrams from your matter data.
Build the exact view you need, right when you need it. Describe it in plain language, and Clio Work builds an interactive tool from your matter data, such as a case chronology or a settlement calculator. Download it and share it with clients and colleagues.
Lay out a tax controversy timeline
Lays out the key events in an audit, appeal, or Tax Court case.
Create This Visualization
Using visualizations, create an interactive timeline of the audit, notices, protests, appeals, and court deadlines, with the statute of limitations date clearly marked. Use the IRS notices and filings in this matter.
Compare income across tax years
Compares income and deductions across tax years.
Create This Visualization
Using visualizations, create an interactive chart comparing income, deductions, credits, and tax owed for each year, and flag any change greater than 20 percent. Use the tax returns in this matter.
Summarize proposed IRS adjustments
Shows each proposed IRS adjustment and the tax and penalties tied to it.
Create This Visualization
Using visualizations, create an interactive table and chart of each proposed adjustment with the tax year, amount, penalty, and the client's position, with totals by year. Use the examination report or notice of deficiency in this matter.
Compare the tax cost of entity structures
Compares the tax cost of different entity structures.
Create This Visualization
Using visualizations, create an interactive side-by-side chart comparing federal and state tax under sole proprietorship, partnership, S corporation, and C corporation treatment. Use the projected income and owner details from this matter.
Project estate tax across scenarios
Shows projected estate tax under different planning scenarios.
Create This Visualization
Using visualizations, create an interactive chart comparing projected estate and gift tax under the current plan and two alternative planning scenarios I specify, with the assumptions for each. Use the asset summary in this matter.