Ryan Gaglio

Ryan advises private equity sponsors, emerging growth companies, venture capital investors, and public companies on the tax aspects of complex mergers and acquisitions and other strategic transactions. His practice spans buy-side and sell-side acquisitions, leveraged buyouts, mergers, dispositions, rollover and earnout structures, inbound and outbound international tax planning, distressed transactions, and fund-related matters. 

In addition to his M&A tax practice, Ryan counsels clients on public offerings, de-SPAC transactions, Umbrella Partnership-C Corporation (Up-C) structures, real estate investment trust (REIT) structures, and take-private transactions. He also represents clients in tax audits and disputes before the IRS, the California Franchise Tax Board, the California Department of Tax and Fee Administration, and in administrative appeals and court challenges before the California Office of Tax Appeals, California superior courts and courts of appeal, U.S. district courts, and the U.S. Tax Court. Ryan previously served as partner and head of the tax practice of a national firm.

Ryan also has extensive experience advising 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.