San Diego · Tax Strategy

San Diego Tax Attorney

Tax counsel for SD-based founders, family-owned operators, professional services practices, and high earners whose income mix and entity structure justify substantive planning, applied with Big Four Mergers and Acquisitions Tax depth.

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The Background

Tax due diligence on hundred-million-dollar deals, applied to your structure.

The firm’s principal trained in Mergers and Acquisitions Tax at Deloitte in Los Angeles and PwC in Silicon Valley, conducting tax due diligence on transactions valued in the hundreds of millions of dollars, and applies that depth to SD-based clients.

What SD-Based Tax Counsel Covers

The full California overlay on a high earner’s position.

Tax Strategy Memoranda

Entity structure, S-corporation election timing, qualified business income deduction analysis, retirement plan strategy, charitable giving, and any planned transactions, addressed in writing.

Multi-State Residency

Residency planning between California and the no-income-tax states, structured so the change of residency holds up under audit.

Qualified Small Business Stock

QSBS planning under the post-OBBBA framework, where the exclusion turns on decisions made at issuance and maintained over the holding period.

The PTET Election

The Pass-Through Entity Tax election under California’s recently enacted state-level provisions, modeled for the SD-based owner.

S-Corp Franchise Tax

The 1.5 percent California state-level franchise tax on S-corporations modeled into every S-election analysis.

Sales-Tax Nexus & M&A Overlay

Sales-tax nexus under post-Wayfair economic nexus rules, and the state-specific overlay on every M&A transaction.

What the Firm Delivers

A written Tax Strategy Memorandum, tied to authority.

Most SD tax engagements produce a written Tax Strategy Memorandum addressing the client’s situation. The memorandum identifies the positions currently in place, the planning opportunities the current structure does not capture, and the specific changes the firm recommends.

Each recommendation is tied to the controlling authority. Year-by-year savings are projected against stated assumptions. Most Tax Strategy Memorandum clients save between $10,000 and $100,000 annually after implementation.

Strategy vs. Compliance

The CPA is doing the job. The structure is wrong.

Most tax returns get filed correctly. The return that gets filed is often not the return that should have been filed. The CPA reconciles the books, applies the deductions the client documents, and produces a return that is technically correct given the structure in place.

The structure is what most SD business owners have never had evaluated. Tax strategy is the work that happens upstream of the return.

Residency Planning

One of the highest-leverage positions available to SD high earners.

For SD-based individuals with the flexibility to choose where they spend time, multi-state residency planning between California and the no-income-tax states is one of the highest-leverage tax positions available. The firm runs the residency analysis and structures the relocation and the subsequent presence-tracking framework so the change of residency holds up under audit.

Related

This page is general guidance, not legal advice on any specific matter. Reading it does not create an attorney-client relationship. Attorney-client relationships are formed only on a signed engagement agreement.

By Appointment · Boutique Practice

Send what’s in front of you.

The recent return, the entity structure as it stands, the pending transaction, the residency question, the question your CPA could not answer. The firm responds within one business day with a written proposal and a preliminary read. The first email is at no charge.

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