Christopher Karachale

Christopher A. Karachale

Partner

  • Print Page
  • Email Page
  • Share this page
Corporate
Corporate
San Francisco

Christopher advises individuals, businesses, non-profits, and government agencies on a range of tax planning and tax controversy matters at the federal, state, local, and international levels. He also serves as outside general counsel to small and midsized companies in need of corporate and general legal advice.

Christopher’s work on federal tax matters ranges from income tax controversies involving individuals and businesses to partnership structuring and corporate mergers and acquisitions. He regularly works with entrepreneurs and start-up companies, and is one of the leading practitioners on qualified small business stock and related section 1202 issues.

At the state level, in addition to income tax-related matters, Christopher counsels individuals and entities on issues involving California property and sales and use taxes. In the international context, he has extensive experience with voluntary disclosures and related planning matters, as well as in-bound and out-bound corporate structuring.

Christopher has published extensively, with articles appearing in Tax Notes, the California Business Law Practitioner, and Law360. He also is a frequent speaker on tax issues to audiences in the United States and abroad. Christopher is certified as a legal specialist in taxation law by the California Board of Legal Specialization.

Publications

"New Guidance on Qualified Small Business Stock Requirements," Tax Notes (July 2017)

“Taxpayers Face Offshore Account Disclosure Dilemma,” co-author, Law360  (April 2017)

"Delinquent Filers Despair: IRS's Dirty Dozen List Demonstrates Ongoing Dangers," co-author, Tax Law Alert (March 2017)

"What is Willfulness? The Streamlined Disclosure Program and What We Know," co-author, Tax Law Alert (December 2016)

"Qualified Small Business Stock Under IRC 1202: Tax-Free Money for the Masses?" California Business Law Practitioner (Summer 2016)

"When does a TIC Agreement Create a Partnership?" co-author, Tax & Real Estate Law Alert (June 2016)

"Section 1202 - Qualified Small Business Stock, A Recipe of 100% Gain Exclusion," Tax Law Alert Video (January 2016)

"FBAR Filing Fiascos Forthcoming? Blame Congress – Not the IRS," co-author, Tax Law Alert (August 2015)

"Taxpayers Must File FBARs By June 30, 2015," co-author, Tax Law Alert (June 2015)

"IRS Reminder: Foreign Account and Asset Reporting Deadlines are Fast Approaching," co-author, Tax Law Alert (April 2015)

"IRS Dirty Dozen – Increased Risks for Taxpayers with Undisclosed Overseas Accounts," co-author, Tax Law Alert (January 2015)

"Still Opportunities for S Corporation Elections to be Effective for 2014," co-author, Tax Law Alert (January 2015)

"Qualified Trades or Businesses for QSBS Defined," Tax Law Alert (September 2014)

"Taxation of Employer Provided Automobiles – Baby You Can Drive My Car," Employee Benefits Law Alert Video (April 2014)

"Foreign Accounts and FATCA," co-author, Tax Law Alert (April 2014)

"Qualified Small Business Stock – An Explanation and Update," The Marin Lawyer (January 2014)

"Property Tax Relief for Tenants of California Public Retirement Systems," co-author, Tax Law Alert (June 2013)

"Will LLCs be Obsolete for Holding Real Estate?," co-author, Tax Law Alert (April 2013)

"California QSBS Resolution Afoot?," co-author, Tax Law Alert (April 2013)

"2013 Tax Issues," co-author, Corporate Law Alert (February 2013)

"​Fiscal Cliff Resolution Provides Pension Planning Options," Corporate Law Alert (January 2013)

"​Franchise Tax Board Update on Qualified Small Business Stock," Corporate Law Alert (December 2012)

"Constitutional Crisis for Qualified Small Business Stock," Corporate Law Alert (September 2012)

"Foreign Account Disclosures Continue," Corporate Law Alert (August 2012)

"IRC Section 83 Update," Corporate Law Alert (August 2012)

"The Greening Code," The M&A Tax Report, Vol. 20, No. 11 (June 2012)

"Unreasonably Low S Corporation Pay," co-author, Tax Notes, Vol. 135, No. 7 (May 2012)

"Revenge of the Tax Nerds," The M&A Tax Report, Vol. 20, No. 10 (May 2012)

"Form 5471—The Next FBAR," The M&A Tax Report, Vol. 20, No. 9 (April 2012)

"A Tale of Caps and Return of Capital," The M&A Tax Report, Vol. 20, No. 8 (March 2012)

"Occupy Their Options," The M&A Tax Report, Vol. 20, No. 7 (February 2012)

"The Deductibility of Group Bonuses," The M&A Tax Report, Vol. 20, No. 6 (January 2012)

"The ABCs of Foreign Bank Accounts," co-author, Tax Notes, Vol. 134, No. 5 (January 2012)

"Repatriated Dividends—Think Different," The M&A Tax Report, Vol. 20, No. 5 (December 2011)

"Sentence Diagramming for Code Sec. 197 Intangibles," The M&A Tax Report, Vol. 20, No. 2 (September 2011)

"Persistent Partnership Problems Parsed," co-author, The M&A Tax Report, Vol. 20, No. 1 (August 2011)

"S Corporation Planning for the Final Exit," The M&A Tax Report, Vol. 20, No. 1 (August 2011)

"Deducting Restitution Under the Origin of the Claim Doctrine," co-author, Tax Notes, Vol. 132, No. 4 (July 2011)

"Unified Business Enterprise Theory Flies First Class," The M&A Tax Report, Vol. 19, No. 12 (July 2011)

"Options in the Web 2.0 Bubble," The M&A Tax Report, Vol. 19, No. 11 (June 2011)

"Restitution and the Origin of the Claim," The M&A Tax Report, Vol. 19, No. 10 (May 2011)

"What WB Acquisition Says About Attorney-Client Partnerships," co-author, Tax Notes, Vol. 131, No. 1 (April 2011)

"Partnership Agreements: Do Sweat the Small Stuff," The M&A Tax Report, Vol. 19, No. 9 (April 2011)

"Ordinary Losses for Squeezed-out Shareholders," co-author, The M&A Tax Report, Vol. 19, No. 6 (January 2011)

"What to Do if Your Foreign Account Is a PFIC," co-author, Daily Tax Report, Vol. 2010, No. 216 (November 2010)

"Morris Trust and More," The M&A Tax Report, Vol. 19, No. 4 (November 2010)

"Who Pays for Unlawful Imprisonment?" co-author, Los Angeles Daily Journal (September 2010) San Francisco Daily Journal (September 2010)

"Home Workers and the Debate Over "Who's a Statutory Employee" Under the Internal Revenue Code," co-author, Business Law News, Issue 2 (2010)

"Acquiring or Selling the Privately Held Company," The M&A Tax Report, Vol. 19, No. 1 (August 2010)

"When Facilitative Merger Costs May Be Deductible," Bowne Review for CFOs & Investment Bankers (June 2010) abstracted from "Documenting Deductible Deal Costs," The M&A Tax Report, Vol. 18, No. 8 (March 2010)

"Deducting With Occam's Razor," The M&A Tax Report, Vol. 18, No. 11 (June 2010)

"Sovereign Seizures," The M&A Tax Report, Vol. 18, No. 9 (April 2010)

"When Golden Parachutes Rip," co-author, The M&A Tax Report, Vol. 18, No. 8 (March 2010)

"Documenting Deductible Deal Costs," The M&A Tax Report, Vol. 18, No. 8 (March 2010)

"The 409A Hit Parade Continues," The M&A Tax Report, Vol. 18, No. 7 (February 2010)

"Can Home Workers Be Independent Contractors?" co-author, California Tax Lawyer, Vol. 19, No. 1 (Winter 2010)

"Home Workers: Employee Status Hidden in Plain Sight," co-author, Tax Notes, Vol. 126, No. 4 (January 2010)

"Tax and Liability Dictate Business Form," co-author, Business Law News, Issue 3 (2010)

"M&A: What You Need to Know Now 2009," co-author, The M&A Tax Report, Vol. 18, No. 5 (December 2009)

See All Publications

Presentations

“US Income Tax Compliance and Proposed Tax Reforms of the Trump Administration,” co-speaker, American Chamber of Commerce Philippines (October 2017)

"Unrelated Business Taxable Income Issues for Tax-Exempt Entities holding Real Property," Northern California Community Loan Fund (August 2017)

"U.S. Income Tax Compliance and Reporting: Tax Reporting Delinquencies and Considering U.S Investments," co-speaker, American Chamber of Commerce Taipei (October 2016)

"Tax Planning for Your Business Exit," co-speaker, American Chamber of Commerce Bangkok (October 2016)

"IRC Section 1202, Qualified Small Business Stock: Tax-Free Gains for Employees and Investors," East Bay Tax Club June Meeting (June 2016)

"IRC Section 1202, Qualified Small Business Stock: Tax-Free Gains for Employers and Investors," CPE Forum of the Central Coast (June 2016)

"United States Gift and Estate Tax Law: Planning for US Spouses and Related Connections,” co-speaker, AmCham Tax Meeting Webinar (March 2016)

"Qualified Small Business Stock – 2015 General Update," co-speaker, Bar Association of San Francisco (October 2015)

"Small Business Stock: Section 1202 Tax Advantages," Strafford Webinars (August 2015)

"New Tax Developments & The Affordable Care Act," co-presenter, WNDE's 2014 Government Tax Seminar (December 2014)

"Property Tax: Case Study," Real Estate Conference – CalCPA Education Foundation (October 2014)

"Taxation of Personal Injury Awards: Drafting Settlement Agreements Under IRC Sec. 104," co-presenter, BASF Conference Center (May 2014)

"Unrelated Business Taxable Income Issues for Private Equity Investors," Hanson Bridgett (February 2014)

"Employee v. Independent Contractor," "How the U.S. Tax System Works: IRS Employment Tax Audits," "Fringe Benefits for Autos and Other Vehicles," "Accident and Health Plans: Other Accident and Health Issues," "Cafeteria Plans & Educational Assistance Plans," WNDE Government Tax Seminar (December 2013)

"Foreign Account Reporting and the IRS Voluntary Disclosure Programs," CPE Forum of the Central Coast (September 2013)

"Update on Recent IRS Payroll Tax Developments," co-speaker, County Payroll Managers Spring Meeting (April 2013)

“Qualified Small Business Stock,” co-speaker, Keiretsu Forum Investor Academy (March 2013)

“Employee Benefits: Key Employer Issues 2013,” co-speaker, Hanson Bridgett Labor & Employment Seminar (January 2013)

"Outbound Transactions & U.S. Federal Tax," Strafford Webinars (January 2013)

"Understanding Key Tax Issues In Employment Cases," 2012 Employment Law CLE Conference, Colorado Bar Association (May 2012)

See All Presentations

Press

"IRS Still Vague On Large Business Audit Details," Law360 (May 2017)

"How to Combat Errors on Tax Forms," TheStreet (April 2017)

"Tax Disclosures," Taiwan Business Topics (November 2016)

"That time Democrats created a massive tax break for the rich," Politico (October 2016)

Honors

Northern California Super Lawyers, Rising Stars (2013-2017)

Professional Affiliations

The Tax Adviser, Board Member

Education

LL.M., Tax, New York University School of Law (2007)

J.D., University of San Francisco School of Law (2006)

M.A., Stanford University (1998)

B.A., cum laude, Middlebury College (1995)

Admissions And Courts

California

New York

U.S. Tax Court

San Francisco

415-995-5863 Direct Phone
415-995-3407 Fax

Email Attorney

vCard
PDF Bio