Planning
Planning a transaction or liquidity event?
Clarify the tax consequences of equity, QSBS, business sales, real estate, ownership changes, and cross-border decisions before the result is locked in.
Plan before it's locked inGalek Tax Law
Tax planning and controversy, handled as one discipline.
Federal and California tax counsel for founders, business owners, investors, and individuals. From structuring tax-sensitive decisions through defense before the IRS, FTB, California Office of Tax Appeals, U.S. Tax Court, and other federal courts.
Complimentary 30-minute initial consultation · phone, video, or in person
Certified SpecialistCertified Specialist in Taxation Law, State Bar of California Board of Legal Specialization
LL.M. TaxationAdvanced training in federal and state tax law
U.S. Tax Court & Ninth CircuitTrial and appellate tax litigation experience
20+ YearsFocused tax law experience
Your situation
Choose the path that fits the moment.
Controversy
Received an IRS or FTB notice?
Bring the notice, the deadline, and the underlying facts into focus before an audit, penalty, collection issue, or appeal narrows your options.
Get ahead of the deadlineThe position
Good tax planning is built to survive questions later.
Many tax practices focus primarily on either structuring transactions or resolving disputes after they arise. Galek Tax Law brings both perspectives to the same problem. Planning advice accounts for how positions are documented, examined, and defended; controversy strategy begins with the transaction, structure, and tax analysis that produced the issue.
Planning informed by controversy
Effective planning considers the governing authority, factual record, documentation, likely agency response, and the position's defensibility before a transaction closes.
Controversy informed by planning
A dispute is better understood through the transaction, ownership structure, agreements, reporting decisions, and contemporaneous documentation behind the notice.
Built for founders, owners, investors, cross-border taxpayers, and individuals facing consequential tax decisions or disputes.
Business, Founder, and Transactional Tax Planning
Tax planning and transactional counsel for founders, business owners, investors, and consequential transactions before the tax result is locked in.
Build a defensible tax planTax Controversy and Litigation
Representation in audits, appeals, collection matters, penalties, and tax-related court proceedings.
Address the disputeInternational and Cross-Border U.S. Tax
Cross-border U.S. tax planning and controversy counsel for individuals, families, entrepreneurs, and businesses with international exposure.
Navigate cross-border tax
Published tax analysis
Technical writing, applied to practical tax decisions.
Published work in Tax Notes publications, the California Lawyers Association, and Canadian Accountant reflects the same approach used in client matters: careful analysis, defensible positions, and practical judgment before a tax issue becomes contested.
SAFEs and Section 1202: When Does the QSBS Clock Actually Start?
An analysis of whether a SAFE constitutes stock for federal tax purposes, when the Section 1202 qualified small business stock holding period begins, the OBBBA's graduated exclusion regime, and the resulting planning risks for investors, founders, and tax advisers.
Let's Be Reasonable: Sourcing California's Restricted Stock Unit Income
Discussion on California's grant-to-vest formula for sourcing RSU income as one reasonable method, with reasonableness, not the formula, as the regulatory standard.
Jason Galek is a Certified Specialist in Taxation Law, certified by the State Bar of California Board of Legal Specialization.
Verify State Bar certificationConsultation
Start with the facts, the documents, and the decision ahead.
A complimentary 30-minute initial consultation can help determine whether the matter is a fit for the practice. Based in Folsom, the practice serves clients throughout the Sacramento region, California, and nationally in federal tax matters.
