# Tax Cold-Start Interview > 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. - Skill: `zgbrenner/tax-cold-start-interview` (Agent Skill) - Install (CLI): `npx skillmds@latest add zgbrenner/tax-cold-start-interview` - Raw SKILL.md: https://api.skillmd.com/api/skills/zgbrenner/tax-cold-start-interview/raw - Safety review: pending - Works with: Claude Code, Claude.ai, OpenAI Codex - Category: Coding & Dev Tools - Author: zgbrenner (https://skillmd.com/u/zgbrenner) - Updated: 2026-09-17 - Page: https://skillmd.com/skills/zgbrenner/tax-cold-start-interview --- # 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.