The Tax Value of Assets Contributed to a Polish Family Foundation: Cash, Shares, and a Dispute the Supreme Administrative Court Has Yet to Resolve
A Polish family foundation (fundacja rodzinna) is exempt from corporate income tax, yet assets distributed upon its dissolution are taxed at fifteen percent of their value, reduced by the “tax value of the assets contributed by the founder” (wartość podatkowa mienia wniesionego). The statutory definition of that tax value, framed around a hypothetical sale of each contributed asset, fits shares and real estate but fits money awkwardly. Since August 2023 the Director of the National Tax Information Office has consistently held that cash contributed in Polish currency has no tax value, so that capital returned to the founder is taxed in full. Four provincial administrative courts, sitting in Łódź, Poznań, Warsaw, and Kraków, have reached the opposite conclusion, holding that only the surplus over contributed capital may be taxed. The Supreme Administrative Court has yet to rule. This Article sets out the mechanism, examines the two lines of reasoning, and identifies the practical consequences for founders: the form in which assets enter the foundation, the currency of cash contributions, the evidentiary burden created by the asset inventory, and the value of obtaining an individual tax ruling long before dissolution becomes a live question.
Introduction
A family foundation is designed to endure across generations, yet the Act of 26 January 2023 on Family Foundations (ustawa o fundacji rodzinnej, hereinafter the “Family Foundation Act” or “FFA”) also provides for its end, and the tax statute provides for a tax at that end. Upon dissolution, the foundation pays corporate income tax (“CIT”) at fifteen percent of the value of the assets distributed to the founder and the beneficiaries, reduced by the tax value of the assets the founder contributed. A single definition, contained in Article 24q(4) of the Act of 15 February 1992 on Corporate Income Tax (ustawa o podatku dochodowym od osób prawnych, hereinafter the “CIT Act”), determines whether the tax reaches only the appreciation above the founder’s cost or also the capital itself.
For shares, ownership interests, and real estate the answer is comparatively clear. For cash, a dispute has persisted for three years. The Director of the National Tax Information Office (Dyrektor Krajowej Informacji Skarbowej, the authority that issues individual tax rulings, hereinafter the “Director”) maintains that money has no tax value; four provincial administrative courts (wojewódzkie sądy administracyjne) have held otherwise; and the Supreme Administrative Court (Naczelny Sąd Administracyjny, hereinafter the “NSA”) has not yet spoken. This Article describes the mechanism, documents the state of the dispute, and addresses the practical question that matters most: what a founder should do today, long before anyone contemplates dissolving the foundation. References to Polish statutes follow the original numbering, so that “Article 24q(4)” denotes art. 24q ust. 4 of the CIT Act.
The Statutory Mechanism of Taxation upon Dissolution
A family foundation is, as a rule, exempt from corporate income tax (Article 6(1)(25) of the CIT Act). The exemption does not extend to the tax imposed by Article 24q, which attaches to three events: benefits (świadczenia) paid to beneficiaries, hidden profits (ukryte zyski), and assets transferred in connection with the dissolution of the foundation (Article 24q(1)). The rate is fifteen percent of the tax base, and the base is the revenue corresponding to the value of the benefit or of the assets (Article 24q(2)). Things and rights are valued at market prices as of the date of transfer (Article 24q(5) in conjunction with Article 12(5), (5a), (6), and (6a)); money is counted at its nominal value. The foundation itself is the taxpayer, and the tax is payable by the twentieth day of the month following the month in which the assets were transferred or placed at the recipient’s disposal (Article 24q(6)).
Dissolution differs from ordinary distributions in one respect. The revenue corresponding to the value of the distributed assets is reduced by the tax value of the assets contributed by the founder or founders (Article 24q(3)). The tax value is defined as the value not previously recognized, in any form, as a tax-deductible cost, which the founder would have treated as such a cost had the asset been sold for consideration immediately before its contribution to the foundation, capped at the market value of that asset (Article 24q(4)). The reduction is available only upon dissolution. Benefits paid during the life of the foundation are taxed on their full value, regardless of what the founder contributed or in what form.
Three consequences of this construction deserve illustration in figures, because intuition tends to mislead.
First, the tax value is the founder’s cost, not the market value on the date of contribution. Suppose a founder purchased shares for PLN 1 million, that they are worth PLN 3 million when contributed, that the foundation sells them years later for PLN 4 million (a sale exempt from CIT as permitted activity under Article 5(1)(4) of the FFA), and that it distributes PLN 4 million upon dissolution. The tax base is PLN 4 million less PLN 1 million, that is, PLN 3 million, and the tax is PLN 450,000. In practice the foundation must set that tax aside from its own funds before the distribution, so the beneficiaries receive correspondingly less, but the mechanism is unchanged. The appreciation that accrued before contribution (PLN 2 million) is therefore not exempt but deferred: upon dissolution the foundation pays fifteen percent on it, rather than the nineteen percent the founder would have paid on a private sale. The rule also operates in the other direction. If the founder paid more than the asset is worth on the date of contribution, only the market value is deductible, and the pre-contribution loss is forfeited.
Second, the tax value of contributed assets is not the same as the “value of contributed assets” recorded in the asset inventory. The latter is the market value of non-cash assets as of the date of contribution (Article 19(1) of the FFA), used to compute the proportion on which the beneficiaries’ exemption from personal income tax (“PIT”) depends (Article 28 of the FFA). The asset inventory (spis mienia) records both figures side by side: the market value as of contribution and the tax value (Article 27(1) of the FFA). Confusing the two at dissolution ends in a dispute with the tax authority.
Third, the definition in Article 24q(4) is built around a “sale for consideration” of the asset. The entire dispute over cash has grown from that one phrase.
The Position of the Tax Authority: Money Has No Tax Value
Since August 2023 the Director has presented a single, unchanging position. Monetary funds in Polish currency contributed by the founder, whether allocated to the founding fund (fundusz założycielski) or donated during the operation of the foundation, do not constitute the tax value of assets contributed by the founder. The reasoning fits in two sentences: the legislature extended the reduction only to those assets which, upon a sale for consideration, could be recognized by the founder as tax-deductible costs, and such assets are things or rights; as regards money, recognition as a cost would not be possible. In other words, money cannot be sold, so it has no cost, and having no cost it has no tax value.
So read the individual tax rulings of 19 October 2023 (No. 0111-KDIB1-2.4010.341.2023.2.EJ), 6 December 2023 (No. 0111-KDIB1-2.4010.528.2023.1.AW), and 3 June 2024 (No. 0111-KDIB1-1.4010.183.2024.2.RH), preceded by rulings of 23 and 24 August 2023 that were subsequently challenged before the courts. All are available in the Ministry of Finance’s EUREKA database. In the June 2024 ruling the Director spelled out a consequence that many founders overlook: upon dissolution the tax base is the entire value of the distributed assets, irrespective of whether those assets derive from the foundation’s profits or from cash contributed to the founding fund.
In figures: a founder contributes PLN 2 million in cash. The foundation invests conservatively, holds PLN 2.2 million after several years, and is dissolved. On the Director’s view the tax is fifteen percent of the PLN 2.2 million distributed, that is, PLN 330,000, of which PLN 300,000 falls on capital the founder had already taxed once before contributing it. Had the same founder contributed, instead of cash, shares purchased for PLN 2 million, the foundation would pay fifteen percent of PLN 200,000, that is, PLN 30,000. The difference of PLN 300,000 turns solely on the form in which the wealth crossed the foundation’s threshold. In practice the foundation must first set the tax aside, so the amounts available for distribution will be lower, but the scale of the difference remains.
One detail merits attention. In the rulings reviewed here, the Director speaks exclusively of “Polish currency.” For foreign currency the definition in Article 24q(4) operates differently: foreign currency can be sold for consideration, and the cost of its acquisition can be established. The point is revisited below, because a court made it one of its arguments.
Four Judgments of the Provincial Administrative Courts: Only the Surplus Is Taxable
The administrative courts have assessed the Director’s position uniformly and unfavorably. The first was the Provincial Administrative Court in Łódź, in its judgment of 28 November 2023, I SA/Łd 768/23, concerning a founder contributing at least PLN 15 million to the founding fund. It was followed by the Provincial Administrative Court in Poznań (judgment of 4 April 2024, I SA/Po 774/23), the Provincial Administrative Court in Warsaw (judgment of 25 April 2024, III SA/Wa 2379/23, concerning a founding fund of at least PLN 10 million), and the Provincial Administrative Court in Kraków (judgment of 18 October 2024, I SA/Kr 646/24). Each judgment set aside a ruling of the Director to the effect described above, and the later panels expressly invoked the earlier judgments and adopted their reasoning. All four are available in the Central Database of Administrative Court Decisions.
The courts’ reasoning can be summarized in five steps.
First, revenue within the meaning of Article 12(1) of the CIT Act can only be a definitive accretion of wealth, and the return to the founder of the equivalent of what the founder contributed is no such accretion. The courts invoke the settled case law of the NSA on the definitive character of revenue (judgments of 23 October 2019, II FSK 1699/19, and of 16 March 2022, II FSK 1695/19).
Second, the ratio legis of Article 24q(3) was to tax only the surplus over what the founder and the founder’s closest family contributed, that is, the foundation’s distributed profits. The Director’s reading leads to double taxation of the same money: once in the hands of the founder when earned, and again in the foundation when returned.
Third, the mechanism of Article 24q resembles the lump-sum tax on corporate income (ryczałt od dochodów spółek, the so-called Estonian CIT): taxation occurs on a cash basis, upon distribution, and the return of contributed capital is not income under that regime. There is no reason to treat a foundation more harshly than a company.
Fourth, the court in Poznań observed that the PIT Act itself, in Article 20(1g), treats money as one of the forms of assets received upon dissolution, since it separately regulates the case in which “those assets are not money or monetary values.” Money is therefore an asset on the way in and on the way out.
Fifth, the court in Kraków pointed to the absurdity to which the Director’s position leads: a founder who exchanged złoty for foreign currency before contributing would have a tax value, whereas a founder contributing złoty would not. Such differentiation between currencies, in the court’s words, was characteristic of the former political system; today, when currency is exchanged with a few clicks, it has no rational justification.
From these premises the courts in Poznań and Kraków derived a more general proposition: the exclusion from tax value under Article 24q(4) concerns only those assets previously recognized as tax-deductible costs, such as a fully depreciated office building, and not assets whose cost cannot be recognized at all. The Kraków court illustrated the dispute with an example that is, for many founders, precisely their dilemma. Shares purchased for X, contributed to the foundation, and sold by it for X plus 100 yield, upon dissolution, a tax on 100. Cash of X contributed to the foundation, which buys the same shares and sells them for X plus 100, yields, on the Director’s view, a tax on the entire X plus 100. Economically the two transactions are identical.
Two considerations temper the comfort this line of authority affords. All four judgments were rendered at first instance and none is final, which means that the cases await the Supreme Administrative Court, which as of 12 October 2026 has not yet ruled on Article 24q(4); that the dispute has reached the NSA is also confirmed by the government in its response to the consultation of the statutory review, discussed below. Moreover, the courts differ on one point: Łódź and Warsaw held that the textual reading also favors the founder, whereas Poznań and Kraków candidly conceded that, on a purely linguistic reading, the Director’s inference is correct, and departed from the text because they considered its result irrational. The strongest argument available to the Director is precisely the text of paragraph 4: the cost of a hypothetical sale does not fit money, and in tax law linguistic interpretation takes precedence. This is exactly the point on which the NSA could go either way. The Director has not changed its position, and a court’s legal assessment binds it only in the case in which the judgment was rendered.
Three considerations nevertheless suggest that the NSA will share the view of the provincial courts. The first is its own line of authority on the definitive character of revenue, on which the provincial courts rested their judgments: the return of contributed capital is no accretion of wealth and therefore cannot be revenue. The second is the NSA’s case law on the return of contributions upon withdrawal from a partnership. In its judgment of 13 December 2013, II FSK 152/12, the court adjudicated the PIT position of a partner in a general partnership in liquidation who had contributed real estate in kind. It held that the exemption for revenue from the return of a contribution to a partnership covers not only the original contribution but also its increase by profits retained in the partnership and already taxed, and by the appreciation of the partnership’s assets, because such revenue is either tax-neutral or derives from revenue already taxed and ought not to be taxed again. For the family foundation dispute, how the NSA arrived at that conclusion matters more than the conclusion itself. The court conceded that the wording of the provision favored the authority, yet rejected that reading as “narrowing and disregarding the realities of the taxation of partners in partnerships,” which is precisely what the courts in Poznań and Kraków later did. The judgment was rendered under the law in force before 2011 and concerned a partnership and a contribution in kind, so it is no precedent for Article 24q(4), but it shows that the NSA is prepared to place the prohibition of double taxation above the letter of a provision.
The third consideration is the solution adopted by the legislature itself. For companies, the principle that the return of capital is tax-neutral is written into the statute: the value of assets received by a shareholder in connection with the liquidation of a company is exempt from PIT in the part corresponding to the cost of acquiring or taking up the shares (Article 21(1)(50a) of the PIT Act), and where the shareholder is a CIT taxpayer, that part does not constitute revenue (Article 12(4)(22) of the CIT Act). Only the surplus over the capital committed is therefore taxed, including where the shares were taken up for cash; the legislature is thus perfectly capable of treating contributed money as capital protected from taxation upon liquidation. Where the legislature has excluded the return of committed capital from taxation upon the liquidation of a company, and the NSA has derived the same result from the statute for partnerships, it is difficult to see why a family foundation should be the only vehicle from which capital returns to its owner taxed a second time. This is a strong systemic argument, but not a foregone conclusion: the judgments and provisions cited concern different situations, and the NSA has not yet ruled on Article 24q(4) of the CIT Act.
Practical Implications for Founders
A. Assets Should Enter in Kind, Not as Cash
The form in which wealth enters the foundation is decisive. Shares, ownership interests, bonds, real estate, fund units, and loan receivables are better contributed in kind than sold to raise cash for contribution. A contribution in kind triggers no PIT for the founder; the foundation may later dispose of those assets within its permitted activity (Article 5(1)(1), (3), and (4) of the FFA, subject to the limitation, discussed below, for assets acquired solely for resale); and upon dissolution it deducts the historical cost of their acquisition, up to the market value as of contribution, provided the founder purchased them, since assets received by gift carry no cost. A private sale of shares or ownership interests before contribution means nineteen percent tax on the gain today and cash that, on the Director’s view, will have no tax value tomorrow. Real estate sold after five years from the end of the year of acquisition is, admittedly, outside PIT, but even then what enters the foundation is cash, with the same problem attached.
B. Cash Only in the Amount the Foundation Actually Needs
The founding fund must have a value of at least PLN 100,000 (Article 17 of the FFA), but it may be covered with non-cash assets. Operating costs, a liquidity reserve, and planned acquisitions are natural reasons for a foundation to hold money. Funding it with cash merely because it is more convenient carries a price, set today by the Director’s position and perhaps tomorrow by the NSA.
C. Currency Matters
In the rulings reviewed here the Director speaks exclusively of Polish currency, and the Kraków court, although adjudicating a case about złoty, treated it as self-evident that foreign currency would have a tax value. A foundation that is to invest abroad may be funded in the currency in which it will purchase assets. This is an argument that strengthens the position, not a guarantee: it is an observation in the reasoning of a judgment, not a decision on a foreign-currency contribution, and a conversion without business purpose, immediately before contribution, invites a discussion about the purpose of the transaction and, in the extreme case, about the GAAR clause in Poland. The currency is best justified by the foundation’s investment plans, not by the wish to secure a deduction. One caveat: currency held by a foundation is meant to serve payments connected with its activity (Article 5(1)(6) of the FFA); trading in currencies for the sake of exchange gains falls outside permitted activity and exposes the foundation to twenty-five percent CIT.
D. The Asset Inventory and Evidence of Cost from Day One
The asset inventory, which the founder prepares for the founding fund and the management board updates upon each subsequent contribution, must state the tax value of every asset (Article 27(1) to (3) of the FFA). Evidence should accompany the inventory: purchase confirmations, commissions, and exchange rates on the dates of acquisition (the cost of shares bought for foreign currency is converted at the rate of the purchase date). The valuation of a foreign-currency contribution itself is a different matter: the statute requires conversion at the average rate of the National Bank of Poland for the last business day preceding the contribution (Article 19(2) of the FFA). The burden of proving the cost upon dissolution rests with the foundation, and dissolution may occur twenty years hence, when the founder’s private brokerage account has long ceased to exist.
E. A Tax Ruling Before Dissolution Becomes a Question
Where substantial cash has entered the foundation, there is little reason to wait for dissolution to learn the authority’s position. The foundation may apply for an individual tax ruling today, as may a founder who is only planning to establish one, since Article 14n § 1(4) of the Tax Ordinance Act (Ordynacja podatkowa) extends the protection of a ruling issued on the founder’s application to the future foundation. The answer will in all likelihood be negative, but an appeal to the administrative courts has four judgments behind it, and a final judgment and the ruling issued thereafter afford the foundation the protection of Articles 14k to 14m of the Tax Ordinance Act, so long as the factual and legal circumstances remain unchanged, and do so long before dissolution becomes a live question. The route usually takes two to three years, and the cost of that tax litigation is a fraction of the tax in dispute.
F. What to Avoid
Structures should not be built around a favorable interpretation. Purchasing assets immediately before contribution solely to avoid contributing cash, followed by their prompt sale by the foundation, is an invitation to two disputes at once. The Director already takes the view that a foundation disposing of assets acquired solely for resale acts outside the scope of Article 5 of the FFA and pays twenty-five percent CIT (Article 24r of the CIT Act); in the ruling of 19 October 2023 even the purchase of real estate earmarked from the outset for sale after a year of letting was treated as such a transaction. The exception concerns ownership interests, shares, and securities, which a foundation may acquire also with a view to their disposal (Article 5(3) of the FFA). To this must be added the two-year test contained in the reform bill, discussed below.
The 2027 Reform Bill: The Definition Stays, the Rate Is Set to Rise
The bill amending the PIT and CIT Acts, referred to the Sejm as print No. 3148, does not alter the definition of tax value in Article 24q(4). It does alter the rate: the tax on benefits, hidden profits, and assets distributed upon dissolution is to rise from fifteen to nineteen percent for tax years beginning after 31 December 2026. The dispute over cash would thus gain exactly four percentage points in value. The bill also introduces a two-year test, counted from the end of the year of contribution, for assets contributed to the foundation from its first tax year beginning after 31 December 2026: an earlier disposal of such assets forfeits the exemption. The test covers only assets contributed to the foundation or transferred to it gratuitously, and, according to the explanatory memorandum, every such asset irrespective of its kind. Assets the foundation has purchased, including purchases made with contributed money, remain outside the test. A temptation thus arises to contribute cash rather than assets, and that is precisely why the price of that temptation upon dissolution should be known in advance. A full account of the changes and of the transitional provisions appears in the firm’s analysis of the 2027 reform of Polish family foundation taxation.
Nor does the legislature intend to settle the dispute over cash. During the consultation of the government’s statutory review of the Family Foundation Act, one law firm proposed that Article 24q(4) be amended to state expressly that the tax value also comprises monetary funds contributed by the founder, in the amount contributed. The Ministry of Finance replied that no legislative work was being conducted in that area, and the Ministry of Economic Development and Technology considered a categorical assessment of the proposal premature, since the issue “is to be resolved by the NSA” (table of comments on the draft review of the Family Foundation Act, 23 September 2026, comment No. 57). That is an official confirmation that the dispute has reached the NSA and that the government would rather await its outcome than pre-empt it.
There is an inconsistency in this. The same review, in describing a future and as yet merely debated model of foundation taxation, contemplates an entry tax on assets other than money and a rule under which benefits would be paid first out of profits earned and only thereafter “out of the foundation’s other assets (which do not generate taxable income).” In the model the Ministry is only beginning to design, a distribution out of capital rather than out of profit is thus not to create income. In the model currently in force, the same Ministry taxes the return of capital in full where that capital was contributed in złoty. It would be difficult to find a clearer demonstration that the problem lies in the letter of Article 24q(4) rather than in the nature of the tax.
Questions Frequently Raised by Founders
Is cash contributed to the founding fund taxed upon the liquidation of a family foundation?
On the Director’s view, yes, in full, because it has no tax value. On the view of four provincial administrative courts, no, because only the surplus over contributed capital is taxable. The NSA has not yet ruled, and the Director applies its own position.
Can contributed cash be deducted when benefits are paid to beneficiaries?
No. The reduction by tax value applies exclusively to assets transferred in connection with the dissolution of the foundation. Benefits are taxed on their full value.
What is the tax value of shares contributed to a family foundation?
The founder’s cost of acquisition, including commission, capped at the market value as of contribution. Shares received by gift have a cost of zero, and inherited shares take over the cost incurred by the deceased (Article 22(1m) of the PIT Act). Appreciation accrued before contribution is not taxed when the foundation sells; the tax arises only when benefits are paid or upon dissolution.
Does foreign currency have a tax value?
In the rulings reviewed here the Director speaks only of Polish currency. The Provincial Administrative Court in Kraków, adjudicating a case about złoty, assumed that foreign currency would have a tax value. That is an argument, not a certainty.
How are beneficiaries taxed upon dissolution?
The founder and the founder’s closest relatives in the so-called zero group benefit from a PIT exemption in the proportion corresponding to the assets contributed by that founder (Article 21(1)(157) and Article 21(49) of the PIT Act). Persons in tax groups I and II pay ten percent in the part corresponding to the same proportion and fifteen percent on the remainder, as do persons outside the family (Article 30(1)(17) of the PIT Act). The foundation’s CIT under Article 24q is independent of this and is borne by the foundation itself.
Conclusion: Seven Points to Retain
- Upon the dissolution of a family foundation, CIT at fifteen percent (the bill provides for nineteen percent) is charged on the value of the distributed assets less the tax value of the assets contributed; no such reduction applies to benefits.
- The tax value is the founder’s cost, not the market value as of contribution; pre-contribution appreciation is deferred, not exempt.
- Since August 2023 the tax authority has denied cash in złoty any tax value; four provincial administrative courts (Łódź, Poznań, Warsaw, and Kraków) have held otherwise, and the NSA is silent.
- Assets should be contributed in kind, cash only in the amount the foundation needs, and preferably in the currency in which it will invest.
- The tax value should be entered in the asset inventory and the evidence of cost secured today.
- Where substantial cash is involved, an application for a tax ruling and, after refusal, a complaint to the court merit consideration; a judgment affords the foundation protection years before dissolution.
- Structures should not be built around an interpretation: assets acquired solely for resale (other than securities) risk twenty-five percent CIT, and the bill adds a two-year test for assets contributed from 2027.
A family foundation is an instrument for decades, and most founders will never witness its dissolution. But the tax value of assets contributed to a family foundation arises on the day of contribution, and from that day it can either be documented or lost. Where cash is to form a substantial part of the contribution to a foundation, the consequences are worth calculating, preferably in a written tax opinion, before they become irreversible.
The law is stated as of 14 October 2026. This Article is for general information only and does not constitute legal advice in any individual matter.
Robert Nogacki is a Polish attorney at law (radca prawny), the founder and managing partner of Kancelaria Prawna Skarbiec (Skarbiec Law Firm), which has operated continuously since 2006.
The law is equal for everyone, but the parties rarely are: on one side stands an organization with time, money, and lawyers, on the other a person with one business, one nest egg, and one life.
Clients rarely come to him with a legal problem. They come with a problem that also has a legal side: an audit that began with a single invoice, money entrusted to someone who has disappeared, a company that has to be passed on before it is too late. Most such matters are decided long before the first letter is written, in decisions made without asking and in deadlines nobody remembered. So he begins by asking how the client got here, not what the client should have done.
He advises entrepreneurs and families from more than a dozen countries, including those whose accounts the tax office has just seized and who do not know what to do tomorrow morning. He defends them in tax audits, customs and fiscal inspections, disputes with the tax authorities, and criminal tax proceedings. He represents victims of investment fraud and Ponzi schemes. He helps families set up family foundations and plan succession, so that a life’s work outlasts a single generation.
Not every case can be won. Every case can be run so that the client knows where they stand. Since 2006 he has represented the victims in the WGI case (Warszawska Grupa Inwestycyjna, the Warsaw Investment Group), one of the longest criminal cases in the history of the Polish financial market, because some things must not be left half finished, even when they take two decades. In the case of the collapsed cryptocurrency exchange Zonda (Zondacrypto, operated by BB Trade Estonia OÜ), he represents several hundred victims in the criminal investigation conducted by Poland’s National Prosecutor’s Office and in the Estonian bankruptcy proceedings.
Kancelaria Prawna Skarbiec is listed in the rankings of Poland’s largest tax advisory firms published by Dziennik Gazeta Prawna and Rzeczpospolita, and it is a four-time recipient (2015 to 2018) of the European Medal awarded by the Business Centre Club and the European Economic and Social Committee. Robert Nogacki publishes regularly, in the press and on the firm’s website, for people who have a problem rather than a law degree, because a legal opinion the client cannot understand protects only the lawyer.
He believes that the best legal advice is the kind that means the client never has to appear in court.
