Business Tax Consulting

Strategic tax counsel for the transactions and controversies that actually move the needle

M&A structuring, R&D credits, IRS audit defense, and exit planning for Bay Area business owners, founders, and operators. Led by Alfonso Nuñez, CPA and JD, with 20+ years of corporate and international tax experience at the Managing Director and Partner level.

  • CPA + JD
  • 20+ Years Corporate Tax
  • IRS Controversy Specialist
  • M&A Tax Planning
  • San Jose, CA
  • Fixed-Fee Engagements
Schedule a Free Consultation (408) 383-9870

No commitment. 30 minutes. Al evaluates your specific transaction or controversy and tells you honestly whether SVT is the right fit.

Highly rated on Google

Tax compliance is about filing what already happened. Business tax consulting is about changing what will happen. The difference between the two is where most of the real money gets made, or lost.

Silicon Valley Tax now offers a dedicated Business Tax Consulting practice for clients who need strategic counsel on transactions, R&D positions, accounting method changes, and IRS disputes. The work is led by Alfonso Nuñez, CPA and JD, who spent the last 20+ years doing exactly this kind of work at the Managing Director and Partner level, focused on M&A planning, IRS controversy, and complex tax matters for business owners and high-net-worth individuals. Al brings that experience directly to SVT clients.

This practice sits on top of the routine compliance work. If you need your 1120, 1120S, 1065, or K-1 filings handled, see our entity tax preparation page. If you have a deal to structure, a credit to defend, an exam letter from the IRS, or an exit coming up in the next two years, you are in the right place.

What We Do

Three practice areas where getting the tax right is worth real money

M&A and Transaction Tax

The structure of a deal determines how much of the proceeds you keep. Asset vs. stock, election choices, NOL analysis, and founder-specific planning can swing the after-tax outcome by seven figures on a mid-market transaction. This is where we spend most of our engagement time.

Asset vs. stock deal modeling and election analysis
§338(h)(10) and §336(e) elections for S-corp targets
§382 NOL limitation analysis for acquirers
F-reorganization structuring for S-corp targets
§1202 qualified small business stock planning for founders pre-exit
Installment sale structuring and earnout tax treatment
Buy-side and sell-side tax due diligence support
Purchase price allocation (§1060) and opening balance sheet
Tax advisor reviewing M&A transaction documents at desk

R&D Credit, §174 R&E Capitalization & Accounting Methods

Most companies doing qualifying research leave five to seven figures in unclaimed R&D credits on the table every year. The §174 TCJA change, now modified by the One Big Beautiful Budget Act, has added complexity that punishes companies without a well-documented position. We build and defend those positions.

IRC §41 R&D tax credit study and substantiation
§174 R&E capitalization compliance and planning
Accounting method changes via Form 3115
Cash to accrual conversion for growing businesses
§263A UNICAP analysis for manufacturers and retailers
§263(a) repair vs. capitalize analysis for real property owners
Tax professional reviewing R&D credit documentation and financial analysis

IRS Controversy, Audit Defense & Tax Opinions

An IRS examination is not a paperwork exercise. It is an adversarial proceeding where what you say in your first response sets the boundaries of everything that follows. Al has a JD and 20+ years of controversy work, including examination representation, appeals, and Tax Court matters. He knows how these unfold and how to defend a position from the first contact letter.

IRS examination representation and audit response management
IRS Office of Appeals representation
Tax Court petition and pre-litigation strategy
Voluntary disclosure programs and amended return strategy
Penalty abatement (reasonable cause, first-time abatement)
Written tax opinions for material or aggressive positions
Uncertain tax position analysis and documentation (ASC 740-10-25-6)
Attorney and CPA reviewing IRS correspondence and tax controversy documents

Who Leads This Practice

Meet Alfonso Nuñez

Alfonso Nuñez, CPA and JD, Senior Tax Partner at Silicon Valley Tax

Alfonso Nuñez

Senior Tax Partner, Silicon Valley Tax

CPA. JD, William S. Boyd School of Law, University of Nevada, Las Vegas. 20+ years corporate and international tax experience.

"Tax consulting is not about finding loopholes. It is about understanding the code well enough to structure what your client is already doing in the most defensible and tax-efficient way possible. The JD matters most when the IRS disagrees, because at that point you are not just doing tax, you are doing law."

Foundation

Al holds both a CPA license and a JD from the William S. Boyd School of Law at the University of Nevada, Las Vegas. That combination is uncommon at the practitioner level and particularly valuable in controversy work, where the difference between a well-reasoned position and an exposed one often comes down to how an argument is framed and documented from the start.

Managing Director at Andersen Tax, San Francisco

Al spent a significant part of his career at Andersen Tax's San Francisco office, reaching the Managing Director level. Andersen Tax is a national firm built almost entirely around complex tax consulting, which means the work is transactional, advisory, and controversy-focused by design. That environment sharpens a different set of skills than a compliance-heavy practice, and Al brought those skills with him.

Partner at RSM US LLP

Al also served as a Partner at RSM US LLP, the fifth-largest accounting and advisory firm in the country. At the Partner level at a firm of that scale, the work is concentrated in complex clients with real stakes: multi-entity structures, cross-border transactions, significant R&D positions, and contested IRS matters. That is the depth of experience Al now applies at Silicon Valley Tax.

Focus Areas

Al's primary focus is M&A planning, IRS controversy, and complex tax matters for business owners and high-net-worth individuals. He works with clients on the transactions and positions where getting the tax wrong costs real money, and where having a CPA with a JD at the table changes the outcome.

When to Engage

If you recognize one of these situations, the conversation is overdue

You're selling your business

Sell-side tax structuring should start 12 to 18 months before close, not 30 days. The election choices, installment sale planning, and entity structure available to you on the day you sign the LOI are almost entirely determined by what you did before that day.

You're acquiring a business

Buy-side tax diligence turns up the liabilities the seller's CPA didn't catch, evaluates available NOLs and their §382 limitations, and determines how to structure the purchase price allocation to maximize your future deductions.

You're an R&D-active company

Most companies doing qualifying research have not done a proper §41 credit study. The §174 capitalization rule change makes the documentation even more important. Unclaimed credits routinely total five to seven figures over a three-year lookback.

You received an IRS notice or examination letter

Representation matters, and it matters from the first response. What you put in writing to the IRS in the early stages shapes the scope of everything that follows. Al has handled examinations at all levels, including Appeals and Tax Court, and knows how to manage the process from the front end.

You're a founder approaching a liquidity event

§1202 QSBS exclusion, lockup planning, installment sale structuring, and charitable remainder structures are all decisions that must be made before the deal closes. A founder who waits until after the term sheet lands has already given up some of the planning options.

Your current CPA says "we don't do that"

On M&A structuring, R&D credits, controversy representation, or accounting method changes, many good compliance-focused firms simply do not have the personnel to do this kind of work. SVT can take the consulting engagement without displacing your existing preparer if you want to keep them for routine filings.

How It Works

Scoped engagements, defined deliverables, no guesswork on fees

  1. 1

    Free 30-minute scoping call

    Al evaluates the specific transaction, credit position, or controversy you are dealing with and tells you honestly whether SVT is the right fit. If the work belongs somewhere else, he will tell you that too.

  2. 2

    Scoped engagement letter from Silicon Valley Tax

    One engagement letter, fixed fee or hourly with a capped budget, with specific deliverables tied to specific dates. No open-ended retainers for defined-scope work, no surprise invoices at the end.

  3. 3

    Technical work product delivered in your preferred format

    Memo, written opinion, election analysis, audit-defense package, or credit study, delivered in the format your CFO or outside counsel prefers. The output is designed to be used, not filed.

  4. 4

    Integration with your routine compliance work

    We coordinate with your existing tax preparer to make sure the consulting position flows correctly into the return. If you want one firm doing everything, SVT handles the routine entity filings too via our entity tax preparation practice and our full suite of services.

The right tax structure is a business decision, not a filing exercise

Schedule a free 30-minute scoping call with Al Nuñez at Silicon Valley Tax in San Jose. He will review your transaction, controversy, or credit position and give you an honest read on what the exposure is and what can actually be done about it.

Fixed-fee or capped-budget engagements. No open-ended hourly commitments for defined-scope work.

Schedule a Free Consultation (408) 383-9870
Ready to talk? Free 30-minute consultation, no obligation. Schedule a Free Consultation (408) 383-9870