As a Partner in Berliner Cohen’s Tax and Corporate Group, Tyler Shewey counsels individuals and business entities on a wide range of tax and business matters. Tyler’s clients range from small startups to established companies in varied industries including real estate, technology, health care, construction, and agriculture.

Tyler’s tax practice includes individual and business income tax planning, as well as federal and California income tax, California sales tax, and California employment tax controversy matters before the following agencies:

• Internal Revenue Service (IRS), including audit, appeals, petitions to United States Tax Court, and collections
• California Franchise Tax Board (FTB), including audit, protest, appeals to Office of Tax Appeals (OTA), and collections
• California Department of Tax and Fee Administration (CDTFA)
• California Employment Development Department (EDD)

In addition, Tyler advises companies and investors on complex business matters including the following:

• Corporation, limited liability company (LLC), and other business entity formation and governance
• Investor equity and debt financing transactions
• Employee equity compensation, including buy-sell agreements
• Mergers and acquisitions (M&A), including tax-free reorganizations
• Stock and asset sale transactions
• Service agreements and other business contracts

Before joining Berliner Cohen, Tyler practiced law as a corporate associate at a Palo Alto law firm, where he worked with technology companies on business transactions and SEC filings and disclosures. He also practiced law at a New York law firm, where he worked with companies to draft merger documents, prepare SEC filings, and provide counsel on employee benefits.

Representative Cases

• Internal Revenue Service (IRS) audits, appeals and petitions – Represented numerous real estate and health care clients in negotiating favorable resolutions with IRS revenue agents, appeals officers, and counsel
• Internal Revenue Service (IRS) collections – Represented numerous clients in successful Offer in Compromise (OIC) applications and other collection alternatives with IRS revenue officers and appeals officers
• California Franchise Tax Board (FTB) audits, protests and appeals – Represented clients in negotiating favorable resolutions in FTB audits, protests, appeals to Office of Tax Appeals (OTA), and collections
• California Department of Tax and Fee Administration (CDTFA) – Counseled clients on favorable resolutions of sales tax audits with CDTFA in industries ranging from food service to technology
• California Employment Development Department (EDD) – Advised clients on California worker classification audits in industries including construction, real estate, health care, and transportation
• Business entity formation and governance – Assisted numerous business clients in forming corporations and LLCs in California and Delaware, completing required business filings, and maintaining legal compliance
• Investor equity and debt financing – Advised business clients on capital structure involving equity and debt, including capital calls
• Employee equity compensation – Represented executive employees on stock options, restricted stock, and other forms of equity compensation
• Equity financing – Represented Peerbridge Health, Inc. in its Series B Preferred Stock financing
• Mergers and acquisitions (M&A) – Represented DriversEd.com in its merger with I Drive Safely
• Asset purchase – Represented Infrascale, Inc. in its acquisition of assets of Eversync Solutions, Inc.

Personal

• Born in San Jose, California
• Resident of Los Gatos, California
• Married with three children
• Interests include soccer and snowboarding