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.
Tax controversy informs the planning. Tax planning shapes the defense.
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 consultation to assess fit, scope, and next steps · 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.
Tax advice is stronger when the structure, documentation, and reporting position can withstand scrutiny. That perspective also helps focus a dispute on the transaction and records that will determine the outcome.
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 addresses tax questions that affect transactions, compliance, and disputes.
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 consultation assesses fit, scope, and next steps. It does not provide substantive legal advice. Based in Folsom, the practice serves clients throughout the Sacramento region, California, and nationally in federal tax matters.
