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 controversy informs the planning. Tax planning shapes the defense.
Federal and California tax counsel for founders, business owners, investors, and individuals. The practice structures tax-sensitive decisions and defends them before the IRS, FTB, California Office of Tax Appeals, U.S. Tax Court, and other federal courts.
Serving clients throughout California · complimentary 30-minute initial consultation by phone, video, or in person
Your situation
Planning
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 inControversy
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
Tax matters become more difficult when planning, reporting, and controversy are treated as separate problems. The practice is structured around the opposite premise: understand the transaction before defending the return, and understand the potential dispute before recommending the transaction.
Effective planning considers the governing authority, factual record, documentation, likely agency response, and the position's defensibility before a transaction closes.
A dispute is better understood through the transaction, ownership structure, agreements, reporting decisions, and contemporaneous documentation behind the notice.
Tax planning and transactional counsel for founders, business owners, investors, and consequential transactions before the tax result is locked in.
Build a defensible tax planRepresentation in audits, appeals, collection matters, penalties, and tax-related court proceedings.
Address the disputeCross-border U.S. tax planning and controversy counsel for individuals, families, entrepreneurs, and businesses with international exposure.
Navigate cross-border tax
Published tax analysis
Published work in Tax Notes publications, the California Lawyers Association, and Canadian Accountant addresses tax questions that affect transactions, compliance, and disputes.
Analysis of whether a SAFE constitutes stock for federal tax purposes and when the Section 1202 holding period begins.
Analysis of California's grant-to-vest sourcing method and the regulatory standard of reasonableness.
Jason Galek is a Certified Specialist in Taxation Law, certified by the State Bar of California Board of Legal Specialization.
Verify State Bar certificationConsultation
A complimentary 30-minute consultation can help determine whether the matter is a fit for the practice. It does not provide substantive legal advice.
Based in Folsom, the practice serves clients throughout California, including the Sacramento region, and nationally in federal tax matters.
