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Gregory Hartker

Partner

Greg Hartker focuses his practice on domestic and international corporate and partnership tax issues. Of particular focus is planning for intangible property, both outbound and inbound, and efficient supply chain structuring. His international tax background includes matters involving Subpart F, global intangible low-taxed income (GILTI), foreign-derived intangible income (FDII), passive foreign investment companies (PFICs), foreign tax credits, withholding, treaty issues, cost sharing, and cross-border transfer pricing. He has advised on some of the largest and most complex restructurings—with values of multiple $US billions—resulting from recent changes in law.

Greg also represents clients in both taxable and tax-deferred mergers and acquisitions, public and private issuances of debt instruments, and partnership and LLC structuring and operating issues.  His work regularly involves M&A transactions valued in the multiple $US billions as well as transactions involving emerging growth and start-up companies.

Greg regularly lectures for professional and industry groups and events (including TEI, the TEI-SJSU High Tech Tax Institute, and the Pacific Rim Tax Conference, among others) on various topics relating to international tax provisions, and under Subchapters C and K.

Areas of focus and recent presentations include:

  • IP planning and structuring for intangibles
  • Practical issues in cross-border M&A, after the Tax Cuts and Jobs Act
  • 2020 Final Regulations: FDII-focus on intangible property
  • International IP planning: Importance of coordination and communication between tax and IP lawyers
  • Corporate restructuring in light of enacted tax legislation, BEPS
  • Current US trends impacting international planning and traps for the unwary
  • Offshore issues for private equity funds
  • Future of international taxation of intangibles and the US Response
  • Base Erosion and Profit Sharing (BEPS): Organisation for Economic Co-operation and Development (OECD) update and developments
  • Tax Cuts and Jobs Act: Impact on international tax and transfer pricing
  • Other tax reform “highlights” and the “certainty” they may bring
  • Doing business overseas: Choice of entities and treaty concepts
  • Dual consolidated losses
  • US tax reform overview
  • Tax reform: Foreign derived intangible income
  • Current and anticipated developments affecting taxation of partnerships

Prior to joining Morgan Lewis, Greg was a partner in the tax practice of another international law firm in San Francisco.

  • Georgetown University Law Center, 1998, LL.M., With Distinction
  • Duquesne University School of Law, 1997, J.D.
  • Duquesne University, 1997, M.B.A., With Honors
  • Kalamazoo College, 1994, B.A.
  • California

Recommended, Tax: US taxes: non-contentious, The Legal 500 US (2025)

Highly Regarded, Transactional Tax, United States, International Tax Review's World Tax Guide (2025)

Member, San Francisco & Silicon Valley Tax Firm of the Year, International Tax Review (2018)

Member, International Editorial Advisory Board, Law360 Tax Authority (2023, 2024)

Member, Practice Group of the Year, Tax, Law360 (2017)