Tax 

The tax practice at GCA Law Partners LLP is focused on meeting the needs of Silicon Valley businesses.

The GCA tax practice encompasses all facets of federal, state, local and international taxation, including the following:

Structuring New and Existing Businesses, Domestic and State Tax Issues. Our tax practice is involved in the formation and structuring of U.S. and foreign based businesses, including choice of entity, compensation, and debt/equity capitalization issues. We provide assistance with domestic and local tax issues, including research credit, net operating loss, and state and local income tax matters. Our practice also deals with electing S corporation treatment and preserving the S election or planning for its termination.

Mergers and Acquisitions. We provide tax structuring advice on mergers and acquisitions for both acquiring and target companies, including structuring to ensure tax-free treatment, preserving and maximizing net operating loss carryovers, maintaining employee equity incentives, addressing “golden parachute” and similar issues.

Venture Capital Partnerships and Limited Liability Companies (LLCs). We provide tax advice on the structuring and implementation of domestic and inbound investment partnerships and LLCs, including advice on various partnership tax issues affecting foreign investors, partners and members. When appropriate, we also provide advice regarding offshore investment vehicles and the most beneficial jurisdictions in which to operate.

Real Estate. The Tax Group supports GCA’s active real estate practice, particularly in the areas of entity formation issues, allocation of income, losses, and entity level debt, passive loss and at risk limitations, and local property tax revaluation issues.

Controversy, including Administrative Resolution of Tax Controversies and Tax Litigation. The Tax Group represents taxpayers at all levels of the administrative process and in court, including the audit process, and in the IRS Appeals Division. Our Tax Group has significant experience representing U.S. multinationals in IRS audits and IRS Appeals.

Employment Tax Audits. Our Tax and Employment Law attorneys work side by side to guide employers through the complexity of an employment tax audit, whether it is at the State of California or federal level. We have represented numerous companies, from small privately held business to large multinational corporations in responding to such audits, negotiating with taxing authorities, appealing assessments, and implementing “best practices” related to worker classification.

Benefit Plan Audits. Our Tax and Benefits and Compensation attorneys have assisted clients through all types of benefit plan audits, from retirement plans such as 401(k) plans to health and welfare plans. We have represented clients in both IRS and Department of Labor audits.

Attorneys in the GCA Tax Group include Amiram J. Givon.