Seth is a tax and corporate attorney with significant experience advising clients on business transactions and representing clients in federal income tax controversies. His practice focuses on mergers; acquisitions; international tax planning regarding Subpart F, intellectual property migrations, inbound investment, cash repatriation, foreign tax credit issues, and permanent establishment exposure; intellectual property transactions; e-commerce transactions; treaty analysis; transfer pricing; high technology tax issues; the taxation of debt, equity, and derivative financial products; and equity compensation. He also shepherds clients through the process of acquiring or being acquired by another company.
Seth's clients include corporations, partnerships, limited liability companies, U.S. persons, and non-U.S. persons conducting business within the United States.
Seth is a contributing author to for the firm’s Law on Purpose blog, which provides insights into the emerging space of social enterprise and impact investing.
Publications & Speaking Engagements
- Speaker, "Reduce Your Startup's International Taxes," RocketSpace (June 2016)
- Speaker, "Debt for Early Stage Companies," RocketSpace (June 2016)
- Speaker, "How to Structure and Prepare Your Company for an Acquisition," RocketSpace (March 2016)
- Speaker, "Tax on Stock Options & Restricted Stock (It's Not Obvious and It May Hurt a Lot)," RocketSpace (December 2015)
- Contributing Author, "Guidance Needed to Clarify Reporting Obligations for Online Marketplaces and Peer-to-Peer Platforms," BNA Tax Management Memorandum (July 2014)
Seth is a member of the San Francisco Bar Association, the State Bar of California, and the American Bar Association.
Seth earned bachelor's degrees with comprehensive honors in political science and Hispanic linguistics and literature from the University of Wisconsin – Madison. He earned his law degree, magna cum laude, and his Master of Laws in Taxation from Georgetown University Law Center, where he received the Thomas Bradbury Chetwood, S.J. prize for ranking first in his LL.M. program. Seth also served as the senior articles editor of the Georgetown Journal of International Law while pursuing his law degree.