Gregory Hartker

Partner

San Francisco Phone +1.415.442.1306 Fax +1.415.442.1001

One Market, Spear Street Tower, 28th Floor//San Francisco, CA 94105-1596//United States

Orange County Phone +1.714.830.0627 Fax +1.714.830.0700

600 Anton Blvd., Ste. 1800//Costa Mesa, CA 92626-7653

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