Insights

Published Work

A selection of Jason J. Galek's published articles and practitioner commentary.

Tax Notes Federal · Jul 23, 2026

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.

Tax Notes State · Mar 2, 2026

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.

CLA Taxation Section 2025 Sacramento Delegation · Oct 24, 2025

Statutory and Constitutional Limitations on the 20-Year Collection Period Under Revenue and Taxation Code § 19255

A proposal examining California's 20-year tax collection period and recommending a nonrenewable limit that penalties, fees, and costs cannot restart.

Tax Notes State · Jun 20, 2022

Severable Water Rights As IRC § 170 Charitable Deduction Property

Principal author of an article discussing the need for guidance on charitable deductions for donation of an entire interest in water rights severable from real property under state law.

Canadian Accountant · Mar 30, 2021

A Taxonomy Of Tax Professionals

A discussion of the various tax professionals in the U.S. and Canada who assist taxpayers in both countries.