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" ... For that reason, the “Covered opinion” rules, which used to span several pages of the pre-2014 version of Circular 230 were removed, and in 2014 were replaced with a much simplier, principals-based approach. The rule now provides that for practitioners to render written advice on any federal tax matter, the tax professional must base the advice on reasonable factual and legal assumptions. There’s a lot more there (again, I encourage you to read it all, above), but the general idea is that practitioners must be reasonable and - most importantly - can’t pretend like they didn’t give the advice that they very clearly gave by including a disclaimer at the bottom of an email. ... "