What does Tax Advisory Memo TA-25-02 say about itself now?

That it is superseded for tax years beginning in 2026, that its figure of 1,160,000 belongs to prior guidance, and that Tax Advisory Memo TA-26-04, issued in March 2026, gives the current figure in section 2. These are fictional training memos.

Why does the client need the old memo kept?

So the firm can explain honestly that the earlier guidance was superseded and show the current source, rather than presenting a changed figure with no history.

Does archiving the old memo settle the Halden advice?

No. The current limit applies only after qualification and the tax-year start date are confirmed. Rohan Mehta's review on the Halden Foods matter comes before release.

Blog · Tax advisory

Why keep a superseded memo instead of deleting it?

An old memo is not authority, but it is history. Rohan Mehta on why the firm archives replaced guidance in place, how a superseded memo describes itself, and what that does for the client who saw the old figure.

You keep a superseded memo because it is evidence of what the firm advised and when, even though it is no longer authority for the current period. At Larkspur & Vance a replaced memo stays in the library, rewritten at the top to state its historical status, the period it no longer governs and the memo that replaced it. Our fictional training pair shows the pattern: Tax Advisory Memo TA-25-02, which used 1,160,000, is archived and points to Tax Advisory Memo TA-26-04, issued in March 2026, which gives 1,250,000 for tax years beginning in 2026. Deleting the old memo would erase the explanation a client is owed.

Rohan Mehta · Tax Partner · September 24, 2026 · 4 min read

Last updated October 2, 2026

What is the difference between authority and history?

Authority is what governs the period you are advising on. History is what governed before. An older memo remains useful as history but is not authority for the current year. The mistake is not keeping the old memo. The mistake is reading it as though it were still in force, and the cure for that is in how the old memo describes itself, not in deleting it.

How does a superseded memo describe itself?

In its own first section. TA-25-02 now opens by saying that it is the superseded memo for the firm's fictional immediate expensing rule, that its figure of 1,160,000 belongs to the prior guidance, and that the figure must not be quoted for tax years beginning in 2026. Its middle section describes what it instructed at the time, in the past tense. Its final section names the replacement, TA-26-04, and points to that memo's section 2 for the current figure and section 3 for the review procedure.

Nobody who opens TA-25-02 can mistake it for current guidance. That is the design.

Why rewrite the old memo rather than just filing it?

Because people find documents by searching, not by browsing a folder marked "archive." A memo that is found by its subject needs to announce its status in the first lines, wherever it was found. Our workspace surfaces the replacement when an associate asks about the subject, and the memo itself says the same thing when opened directly. Two routes, one answer.

What does keeping it do for the client?

It makes the explanation possible. Halden Foods saw last year's memo with the old figure in it. When the current advice carries a different figure, the client is owed a sentence that says the earlier guidance was superseded in March 2026 and here is the current source. Our review standard requires exactly that: explain that the earlier memo was superseded rather than implying that the old memo never existed. You cannot write that sentence honestly if the old memo has been destroyed.

What does keeping it do for the firm?

It preserves the record. The firm's retention policy keeps the source versions used alongside the final issued advice, for seven years after matter closure. If the firm advised a client under TA-25-02 in its period, the retained record needs TA-25-02 as it stood, so that anyone reviewing the file later can see that the advice was correct for its time. An archived memo is part of that record.

What are the rules for the pair?

The current memo states that it is in force, names its period and names what it replaces.
The superseded memo states that it is superseded, names the period it no longer governs and names its replacement.
Neither is deleted.
The two figures are never presented as competing current rules.
A draft that used the old figure identifies the changed line and replaces its citation, with the explanation.

What is still a judgement?

Whether the current figure applies at all. The limit in TA-26-04 applies only after qualification and the tax-year start date have been confirmed. On the Halden matter the source change is identified and the qualification review is mine, and still ahead of release. Archiving the old memo correctly tells an associate where the current line is. It does not tell them that the line fits the client's facts. That part is review, and review is a person.

What should an associate do when they find the old memo first?

Read its first section, which will tell them it is superseded and where the replacement is. Then open the replacement and work from that. Then, if the draft they were checking cites the old memo, identify the changed line, replace the figure and the citation, and write the correction in the form the firm requires: the earlier memo was superseded, the current source is this one, the current figure is that.

What they should not do is treat finding the old memo as a dead end, or treat the old figure as a second opinion. There is only one memo in force for a period. The archived one is kept so that the history can be explained, not so that it can be argued with. If the period itself is unclear, that is a question for review, and on the Halden matter it is still mine.

Q&A

The questions associates ask most about superseded memos are answered below.

Last updated 1 October 2026.

Questions and answers

Is a superseded memo deleted at Larkspur & Vance?: No. It is kept in place as evidence of the change, rewritten at the top to state its historical status, the period it no longer governs and the memo that replaced it.
What does Tax Advisory Memo TA-25-02 say about itself now?: That it is superseded for tax years beginning in 2026, that its figure of 1,160,000 belongs to prior guidance, and that Tax Advisory Memo TA-26-04, issued in March 2026, gives the current figure in section 2. These are fictional training memos.
Why does the client need the old memo kept?: So the firm can explain honestly that the earlier guidance was superseded and show the current source, rather than presenting a changed figure with no history.
Does archiving the old memo settle the Halden advice?: No. The current limit applies only after qualification and the tax-year start date are confirmed. Rohan Mehta's review on the Halden Foods matter comes before release.

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