Tax Cold-Start Interview

Purpose

Conduct a structured, staged interview with a tax practice group — led by a supervising attorney or authorized designee — to gather the information required to populate practice-profiles/tax.md. The skill walks through all eight profile fields in sequence, records every answer, and assembles a filled draft of the profile for the practice group's review and approval. It produces draft legal work product for attorney review — not legal advice and not a final configuration.

Use When

• A team is adopting AgentCounsel and needs to configure practice-profiles/tax.md for the first time.
• A tax practice group is being onboarded to the library and no current profile exists.
• The library is being stood up for the first time and the tax area is included in scope.
• A practice group wishes to revisit or rebuild its profile from scratch rather than make incremental updates.

Required Inputs

• A knowledgeable person from the tax practice group — a supervising attorney or an authorized designee — who can answer questions about the group's jurisdiction, positions, escalation rules, and review requirements.
• Any existing playbooks, templates, source-of-truth documents, or standard-form documents the group already uses, so they can be referenced or cited in the profile.

Do Not Use When

• The group is actively working a live tax matter. This skill configures the library; it does not support an open matter.
• A practice-profiles/tax.md already exists and is current. In that case this is a refresh, not a cold start — though the skill may still be used to rebuild the profile deliberately.
• No authorized person is available to answer. Do not complete the interview with guessed or inferred answers; record all gaps as [CONFIRM: ...] placeholders.
• The purpose is to handle a specific tax matter (use the appropriate matter-level skill for that task).

Legal Safety Rules

• Produce draft legal work product for attorney review. This is not legal advice.
• Never guess or infer an answer to any interview question. If the interviewee cannot answer a question, record [CONFIRM: answer required from practice group] and move on.
• The filled profile is a draft. It must be reviewed and explicitly approved by the supervising attorney or practice group before it governs any AgentCounsel work product.
• Do not invent standard positions, clause preferences, escalation thresholds, or review rules. Record only what the interviewee provides.
• Do not include client-specific facts, client names, matter identifiers, or privileged details in the profile. The profile is a reusable group-level configuration, not a matter record.
• Do not state or imply that any threshold, position, or rule in the profile satisfies a legal requirement under any jurisdiction. Jurisdiction-specific legal obligations are for the attorney to verify.
• Flag every item the interviewee defers or leaves open with a visible [CONFIRM: ...] placeholder so the reviewer can see exactly what is unresolved.

Workflow

Stage 1 — Jurisdictions

Ask the interviewee:

• In which jurisdictions does the group advise — US federal, US state and local (and which states are most common), international, treaty-based?
• Does the group handle cross-border matters routinely, and which treaty relationships drive most of that work?
• Are there sales-and-use, VAT/GST, transfer-pricing, or other transactional regimes the group regularly advises on?
• Are there jurisdictions where the group works only through specified foreign tax counsel, and how is that allocation tracked?
• Are there jurisdictions the group treats as out of scope, requiring specialist outside tax counsel?

Record answers. Mark any unanswered item [CONFIRM: jurisdiction not yet specified].

Stage 2 — Client and Team Context

Ask the interviewee:

• What types of tax matters does the group handle most frequently — planning, controversy, transactional, compliance support, opinions?
• Are clients primarily corporate, partnership/LLC, high-net-worth individual, tax-exempt, or a mix?
• How is the team structured — tax partners, associates, LL.M.-tax specialists, transfer-pricing economists, CPAs supporting the team?
• How does the group coordinate with accountants, transfer-pricing economists, and external tax preparers?
• Are there client categories — financial sponsors, REITs, tax-exempt entities, multinationals — that require special handling?

Record answers. Mark any unanswered item [CONFIRM: client/team context not yet specified].

Stage 3 — Escalation Thresholds

Ask the interviewee:

• Which tax matters automatically require escalation — cross-border structuring, transfer pricing, tax-exempt entity questions, IRS audit / agency inquiry, ruling requests, M&A tax structuring?
• Are there transaction-value or tax-amount thresholds that trigger escalation, and what are they?
• When does a tax position rise to a 'reportable transaction' or other disclosure-required posture that requires immediate review?
• Which tax-opinion requests (will / should / would / more-likely-than-not) require partner-level review regardless of size?
• Who is the designated escalation contact for tax matters, and what is the expected turnaround?

Record answers. Mark any unanswered item [CONFIRM: escalation threshold not yet specified].

Stage 4 — Preferred Output Style

Ask the interviewee:

• Should tax work product default to formal memo format, structuring deck, opinion letter, or controversy-defense memo?
• What level of detail does the practice group expect — executive summary, full citation-supported analysis, both layered?
• Are there house style rules for citation format, levels of assurance (will / should / more-likely-than-not), or 'wandering issues' flagging in tax work product?
• Does the group produce structuring decks or step plans, and if so, in what format?
• Are there particular deliverable types — opinion letters, ruling requests, controversy memos — for which the group has mandatory format requirements?

Record answers. Mark any unanswered item [CONFIRM: output style preference not yet specified].

Stage 5 — Source-of-Truth Documents

Ask the interviewee:

• What is the group's authoritative tax-positions library, and where is it stored?
• Is there a transfer-pricing policy or documentation framework, and how is it kept current?
• What document governs the group's M&A tax-structuring playbook?
• Are there controversy precedents (prior audit defense, prior IRS appeals, prior ruling requests) the group treats as authoritative for similar matters?
• Is there a tax-elections checklist or treasury-checklist the group references?

Record answers and document names. Mark any unanswered item [CONFIRM: source document not yet identified].

Stage 6 — Standard Positions and Playbooks

Ask the interviewee:

• What is the group's default assurance-level framework — when do matters warrant a will opinion, a should opinion, a more-likely-than-not opinion?
• What is the group's default chain-of-authority approach — strict reliance on primary authority, layered approach, or other?
• What is the group's default substance-over-form posture — strict, deferential, mixed?
• What is the group's default position on reportable-transaction disclosure?
• What is the group's default approach to tax-exempt entity matters, if applicable?

Record answers. Mark any unanswered item [CONFIRM: standard position not yet specified].

Stage 7 — Attorney Review Requirements

Ask the interviewee:

• At what stage does attorney review of tax work product become mandatory — initial issue spotting, opinion drafting, ruling submission, controversy filings?
• Are there work-product types for which attorney review is always required regardless of size — any opinion, any IRS submission, any structuring memo on a multi-step plan, any tax position taken on a return?
• What is the designated reviewer's role — handling attorney, supervising tax partner, LL.M. specialist, peer reviewer?
• What is the expected turnaround for opinion review, and how are urgent reviews (filing deadlines, audit responses) handled?
• Is there a formal sign-off step before an opinion is delivered, a ruling is submitted, or a tax position is communicated to the client?

Record answers. Mark any unanswered item [CONFIRM: review requirement not yet specified].

Stage 8 — Prohibited Assumptions

Ask the interviewee:

• Are there facts agents must never assume without explicit confirmation — that a tax position is sustained on audit, that an entity classification is current, that a treaty applies, that a ruling continues to bind, that an exemption is preserved?
• Are there tax-specific risks — substance over form, economic substance, reportable transaction, anti-abuse — where an agent must stop and escalate rather than reason through independently?
• Are there matter types where agents must never proceed beyond intake without direct attorney involvement — opinions, rulings, structuring on multi-step plans, controversy filings?
• Are there prior incidents — adverse audit findings, IRS challenges, sanctions — that should be encoded as explicit prohibitions for agents working on tax matters?

Record answers. Mark any unanswered item [CONFIRM: prohibited assumption not yet specified].

Stage 9 — Assemble the Draft Profile

Compile all answers into a filled draft of practice-profiles/tax.md, populating each of the eight profile sections. For every item that was not answered, insert a visible [CONFIRM: ...] placeholder with enough context for the reviewer to understand what needs to be supplied. Append a list of all open placeholders so the reviewing attorney can see at a glance what remains unresolved.

Output Format

Deliver:

1. Filled draft of practice-profiles/tax.md — all eight sections populated with answers from the interview. Every unanswered item is a visible [CONFIRM: ...] placeholder.
2. Open-items list — an explicit enumeration of every placeholder inserted, with the stage and question it corresponds to, so the reviewing attorney can resolve them efficiently.

Label the entire output: Draft legal work product for attorney review. Not legal advice. This profile draft must be reviewed and approved by the supervising attorney or practice group before it is relied upon.

Attorney Verification Checklist

• [ ] All eight profile sections have been reviewed by a supervising attorney or authorized practice-group representative.
• [ ] Jurisdiction coverage — federal, state, local, international, treaty — is accurately recorded [Verify current law].
• [ ] Assurance-level framework (will / should / more-likely-than-not / reasonable basis) is current and tied to the group's engagement-letter and malpractice posture [ATTORNEY TO CONFIRM].
• [ ] Reportable-transaction disclosure framework reflects current IRS guidance [Verify current law].
• [ ] Tax-positions library references are current and version-controlled.
• [ ] Statute-of-limitations and filing-deadline triggers in any related matters are marked [deadline verification required].
• [ ] No client-specific facts, matter identifiers, or privileged details appear in the profile.
• [ ] All [CONFIRM: ...] placeholders have been resolved or explicitly accepted as pending.
• [ ] The approved profile has been saved to practice-profiles/tax.md and its effective date recorded.
• [ ] A process for periodic profile review and update has been identified.

Full raw SKILL.md

---
name: Tax Cold-Start Interview
description: "Use when a tax practice group is adopting AgentCounsel and needs to configure its practice profile by answering a structured interview covering jurisdictions, client context, escalation thresholds, output preferences, source documents, standard positions, review requirements, and prohibited assumptions."
practice_area: setup
task_type: interview
jurisdictions: []
risk_level: low
requires_attorney_review: true
inputs:
  - "Access to a tax attorney or authorized designee"
  - "The practice group's jurisdictions and client context"
  - "Standard positions, escalation thresholds, and review requirements"
outputs:
  - "Filled tax practice profile draft for attorney review"
related_skills:
  - skills/tax/tax-issue-intake/SKILL.md
  - skills/tax/international-tax-issue-spotter/SKILL.md
  - skills/tax/sales-use-tax-nexus-triage/SKILL.md
tags:
  - setup
  - cold-start
  - practice-profile
  - configuration
  - tax
---

# Tax Cold-Start Interview

## Purpose

Conduct a structured, staged interview with a tax practice group — led by a supervising attorney or authorized designee — to gather the information required to populate `practice-profiles/tax.md`. The skill walks through all eight profile fields in sequence, records every answer, and assembles a filled draft of the profile for the practice group's review and approval. It produces draft legal work product for attorney review — not legal advice and not a final configuration.

## Use When

- A team is adopting AgentCounsel and needs to configure `practice-profiles/tax.md` for the first time.
- A tax practice group is being onboarded to the library and no current profile exists.
- The library is being stood up for the first time and the tax area is included in scope.
- A practice group wishes to revisit or rebuild its profile from scratch rather than make incremental updates.

## Required Inputs

- A knowledgeable person from the tax practice group — a supervising attorney or an authorized designee — who can answer questions about the group's jurisdiction, positions, escalation rules, and review requirements.
- Any existing playbooks, templates, source-of-truth documents, or standard-form documents the group already uses, so they can be referenced or cited in the profile.

## Do Not Use When

- The group is actively working a live tax matter. This skill configures the library; it does not support an open matter.
- A `practice-profiles/tax.md` already exists and is current. In that case this is a refresh, not a cold start — though the skill may still be used to rebuild the profile deliberately.
- No authorized person is available to answer. Do not complete the interview with guessed or inferred answers; record all gaps as `[CONFIRM: ...]` placeholders.
- The purpose is to handle a specific tax matter (use the appropriate matter-level skill for that task).

## Legal Safety Rules

- Produce draft legal work product for attorney review. This is not legal advice.
- Never guess or infer an answer to any interview question. If the interviewee cannot answer a question, record `[CONFIRM: answer required from practice group]` and move on.
- The filled profile is a draft. It must be reviewed and explicitly approved by the supervising attorney or practice group before it governs any AgentCounsel work product.
- Do not invent standard positions, clause preferences, escalation thresholds, or review rules. Record only what the interviewee provides.
- Do not include client-specific facts, client names, matter identifiers, or privileged details in the profile. The profile is a reusable group-level configuration, not a matter record.
- Do not state or imply that any threshold, position, or rule in the profile satisfies a legal requirement under any jurisdiction. Jurisdiction-specific legal obligations are for the attorney to verify.
- Flag every item the interviewee defers or leaves open with a visible `[CONFIRM: ...]` placeholder so the reviewer can see exactly what is unresolved.

## Workflow

**Stage 1 — Jurisdictions**

Ask the interviewee:
- In which jurisdictions does the group advise — US federal, US state and local (and which states are most common), international, treaty-based?
- Does the group handle cross-border matters routinely, and which treaty relationships drive most of that work?
- Are there sales-and-use, VAT/GST, transfer-pricing, or other transactional regimes the group regularly advises on?
- Are there jurisdictions where the group works only through specified foreign tax counsel, and how is that allocation tracked?
- Are there jurisdictions the group treats as out of scope, requiring specialist outside tax counsel?

Record answers. Mark any unanswered item `[CONFIRM: jurisdiction not yet specified]`.

**Stage 2 — Client and Team Context**

Ask the interviewee:
- What types of tax matters does the group handle most frequently — planning, controversy, transactional, compliance support, opinions?
- Are clients primarily corporate, partnership/LLC, high-net-worth individual, tax-exempt, or a mix?
- How is the team structured — tax partners, associates, LL.M.-tax specialists, transfer-pricing economists, CPAs supporting the team?
- How does the group coordinate with accountants, transfer-pricing economists, and external tax preparers?
- Are there client categories — financial sponsors, REITs, tax-exempt entities, multinationals — that require special handling?

Record answers. Mark any unanswered item `[CONFIRM: client/team context not yet specified]`.

**Stage 3 — Escalation Thresholds**

Ask the interviewee:
- Which tax matters automatically require escalation — cross-border structuring, transfer pricing, tax-exempt entity questions, IRS audit / agency inquiry, ruling requests, M&A tax structuring?
- Are there transaction-value or tax-amount thresholds that trigger escalation, and what are they?
- When does a tax position rise to a 'reportable transaction' or other disclosure-required posture that requires immediate review?
- Which tax-opinion requests (will / should / would / more-likely-than-not) require partner-level review regardless of size?
- Who is the designated escalation contact for tax matters, and what is the expected turnaround?

Record answers. Mark any unanswered item `[CONFIRM: escalation threshold not yet specified]`.

**Stage 4 — Preferred Output Style**

Ask the interviewee:
- Should tax work product default to formal memo format, structuring deck, opinion letter, or controversy-defense memo?
- What level of detail does the practice group expect — executive summary, full citation-supported analysis, both layered?
- Are there house style rules for citation format, levels of assurance (will / should / more-likely-than-not), or 'wandering issues' flagging in tax work product?
- Does the group produce structuring decks or step plans, and if so, in what format?
- Are there particular deliverable types — opinion letters, ruling requests, controversy memos — for which the group has mandatory format requirements?

Record answers. Mark any unanswered item `[CONFIRM: output style preference not yet specified]`.

**Stage 5 — Source-of-Truth Documents**

Ask the interviewee:
- What is the group's authoritative tax-positions library, and where is it stored?
- Is there a transfer-pricing policy or documentation framework, and how is it kept current?
- What document governs the group's M&A tax-structuring playbook?
- Are there controversy precedents (prior audit defense, prior IRS appeals, prior ruling requests) the group treats as authoritative for similar matters?
- Is there a tax-elections checklist or treasury-checklist the group references?

Record answers and document names. Mark any unanswered item `[CONFIRM: source document not yet identified]`.

**Stage 6 — Standard Positions and Playbooks**

Ask the interviewee:
- What is the group's default assurance-level framework — when do matters warrant a will opinion, a should opinion, a more-likely-than-not opinion?
- What is the group's default chain-of-authority approach — strict reliance on primary authority, layered approach, or other?
- What is the group's default substance-over-form posture — strict, deferential, mixed?
- What is the group's default position on reportable-transaction disclosure?
- What is the group's default approach to tax-exempt entity matters, if applicable?

Record answers. Mark any unanswered item `[CONFIRM: standard position not yet specified]`.

**Stage 7 — Attorney Review Requirements**

Ask the interviewee:
- At what stage does attorney review of tax work product become mandatory — initial issue spotting, opinion drafting, ruling submission, controversy filings?
- Are there work-product types for which attorney review is always required regardless of size — any opinion, any IRS submission, any structuring memo on a multi-step plan, any tax position taken on a return?
- What is the designated reviewer's role — handling attorney, supervising tax partner, LL.M. specialist, peer reviewer?
- What is the expected turnaround for opinion review, and how are urgent reviews (filing deadlines, audit responses) handled?
- Is there a formal sign-off step before an opinion is delivered, a ruling is submitted, or a tax position is communicated to the client?

Record answers. Mark any unanswered item `[CONFIRM: review requirement not yet specified]`.

**Stage 8 — Prohibited Assumptions**

Ask the interviewee:
- Are there facts agents must never assume without explicit confirmation — that a tax position is sustained on audit, that an entity classification is current, that a treaty applies, that a ruling continues to bind, that an exemption is preserved?
- Are there tax-specific risks — substance over form, economic substance, reportable transaction, anti-abuse — where an agent must stop and escalate rather than reason through independently?
- Are there matter types where agents must never proceed beyond intake without direct attorney involvement — opinions, rulings, structuring on multi-step plans, controversy filings?
- Are there prior incidents — adverse audit findings, IRS challenges, sanctions — that should be encoded as explicit prohibitions for agents working on tax matters?

Record answers. Mark any unanswered item `[CONFIRM: prohibited assumption not yet specified]`.

**Stage 9 — Assemble the Draft Profile**

Compile all answers into a filled draft of `practice-profiles/tax.md`, populating each of the eight profile sections. For every item that was not answered, insert a visible `[CONFIRM: ...]` placeholder with enough context for the reviewer to understand what needs to be supplied. Append a list of all open placeholders so the reviewing attorney can see at a glance what remains unresolved.

## Output Format

Deliver:

1. **Filled draft of `practice-profiles/tax.md`** — all eight sections populated with answers from the interview. Every unanswered item is a visible `[CONFIRM: ...]` placeholder.
2. **Open-items list** — an explicit enumeration of every placeholder inserted, with the stage and question it corresponds to, so the reviewing attorney can resolve them efficiently.

Label the entire output: **Draft legal work product for attorney review. Not legal advice. This profile draft must be reviewed and approved by the supervising attorney or practice group before it is relied upon.**

## Attorney Verification Checklist

- [ ] All eight profile sections have been reviewed by a supervising attorney or authorized practice-group representative.
- [ ] Jurisdiction coverage — federal, state, local, international, treaty — is accurately recorded `[Verify current law]`.
- [ ] Assurance-level framework (will / should / more-likely-than-not / reasonable basis) is current and tied to the group's engagement-letter and malpractice posture `[ATTORNEY TO CONFIRM]`.
- [ ] Reportable-transaction disclosure framework reflects current IRS guidance `[Verify current law]`.
- [ ] Tax-positions library references are current and version-controlled.
- [ ] Statute-of-limitations and filing-deadline triggers in any related matters are marked `[deadline verification required]`.
- [ ] No client-specific facts, matter identifiers, or privileged details appear in the profile.
- [ ] All `[CONFIRM: ...]` placeholders have been resolved or explicitly accepted as pending.
- [ ] The approved profile has been saved to `practice-profiles/tax.md` and its effective date recorded.
- [ ] A process for periodic profile review and update has been identified.