Tax position memos with citations
Memos that take a position on a tax question for a specific client fact pattern and defend it with authority.
- Domain
- Accounting & tax
- Format
- Technical memos of 800 to 4,000 words with statutory and case citations, PDF or DOCX
- Rate
- $80 to $120 per accepted file
- Window
- Opened 2 September 2026 · Closes 28 October 2026
- Attestation
- Required on every file
- Agreement
- Firm or institutional agreement
The call
A tax position memo is an argument with citations: here are the facts, here is the question, here is the authority, here is what we conclude and how confident we are. We are acquiring memos of this kind across corporate, partnership, individual and cross-border matters.
Memos should retain their citations in full. We are not acquiring the underlying client documents.
What qualifies
- Memos prepared for a real client matter
- At least three cited authorities
- A stated conclusion and confidence level, or the firm's equivalent
What is excluded
- Memos on matters currently under examination or in dispute
- Client-identifiable fact patterns
- Memos older than the 2017 reform, unless the position remains current
De-identification
Replace client and entity names with role labels; keep entity types. Convert amounts to ranges where the exact figure would identify the client.
Review
Read by a tax practitioner with at least ten years of practice. Citations are spot-checked.
Rights
Full license transferred to Gridfile at acceptance. Firm agreement required.
GF-0108 · Reviewed by a former Big Four tax director