An advisory-first CPA firm. Year-round partners for business owners, private clients, real estate owners, and the structures behind them.
Business owners, private clients, real estate investors, professional practices, and multi-entity families navigating growth, complexity, succession, and significant financial decisions. Choose the path that best matches your situation.
Entity, compensation, succession, and the years before a buyer is at the table.
Tax-deferred exchanges under Section 1031, DSTs, cost segregation, and keeping property separate from the operating company.
CFC, FIRPTA, treaty elections, and a US-side partner while principals are abroad.
Practice operations, compensation, multi-location groups, and succession when it is time.
The OP Total Net Worth Framework. Assess, Model, Structure, Execute, File, Optimize. The tax return is an output of the relationship, not the product.
Structural inventory of entities, assets, jurisdictions, stakeholders, and capital events.
→ A complete picture of where you standModel how the current structure performs as the business grows, ownership changes, assets move, or a significant liquidity event approaches.
→ Find the cracks before the event exposes themEntity restructuring, timing elections, qualified small business stock (QSBS) under Section 1202, installment sales, tax-deferred exchanges under Section 1031, and trusts.
→ The structural moves that produce the resultsQuarterly roadmap meetings. Elections, structure changes, compliance alignment on a timeline.
→ Ongoing guidance as your business evolvesWe file returns, but only after the strategy is built and stress-tested. Most firms begin here; we get here last.
→ Returns are an output of strategyPre-LOI support. Post-sale capital redeployment. 1031s, DSTs, §453 installment sales, opportunity zones.
→ Liquidity events are a chapter, not the whole bookThree questions. We flag areas worth reviewing in an Assessment. This is not a tax estimate.
For informational purposes only. Results are not tax advice and use of this tool does not establish a CPA-client relationship.
Starting points from what you told us, not a dollar of overpayment.
A short list of planning areas that often apply to the profile you described. Real work is specific to your entities, basis, states, holding periods, and documents.
Flagship engagements. Individual results vary. See all results for the fuller set.
Three years before the sale, we restructured entities, timed elections, and positioned the owner's real estate portfolio alongside the business exit. When the $30M offer came, every dollar moved through a structure that was already in place.
General contractor, Riverside County. $30M exit. $5.8M saved.Case result. Outcomes vary.
The founder's C-corp stock qualified under §1202, but their previous CPA had never flagged it. One conversation uncovered $2.32M in tax-free gains on a $12.5M exit, money that would have gone straight to the IRS.
Founder, Irvine. $12.5M exit. $2.32M QSBS benefit identified.Case result. Outcomes vary.
A seven-figure IRS penalty notice. We built a reasonable cause argument grounded in the client's specific circumstances, represented them through the full process, and the penalty was eliminated entirely. Not reduced. Eliminated.
Executive, San Diego. $1.1M IRS penalty eliminated.Case result. Outcomes vary.
Trust strategy plus Roth conversion timing saved $4.1M in projected estate taxes. The business stays in the family.
Family office, Palm Desert. $4.1M projected estate tax reduction.Case result. Outcomes vary.
FIRPTA withholding reduced from 15% to under 4% via treaty election and timely 8288-B filing.
Canadian seller. FIRPTA withholding reduced from 15% to under 4%.Case result. Outcomes vary.
Multi-property 1031 exchange into DST portfolio, deferring $2.1M in capital gains while producing passive monthly income.
Real estate investor, Orange County. Multi-property exchange under Section 1031 into a DST. $2.1M deferred.Case result. Outcomes vary.
Advisory first. Compliance follows strategy. Then we file the return.
Installment sales under Section 453, ESOPs, and qualified small business stock (QSBS) under Section 1202, mapped to your timeline.
$18M+ in penalties abated. Reasonable cause, audit representation, voluntary disclosure.
Tax-deferred exchanges under Section 1031, DSTs, cost segregation, and opportunity zones. Explore tax-deferred real-estate strategies following a significant transaction.
18+ countries. Treaty elections, FBAR, foreign trusts, dual-status returns.
Trusts, gifting, and Roth conversion timing that protect what you have built.
Entity selection, compensation, accounting support, R&D credits, and state tax nexus planning.
Decades of senior-level experience across tax, business advisory, valuation, and real estate.

Entity structuring, business valuations, and exit strategy. Before O'Brien & Panchuk, Tom spent years at Oracle Consulting. If you're selling, restructuring, or trying to figure out what your business is actually worth, Tom maps the path.

Cross-border perspective across 18+ countries. Treaty elections, FBAR, foreign trusts, dual-status returns. Creator of the Total Net Worth Framework.

Founding Partner of Folkers and Associates CPAs, now part of O'Brien & Panchuk. Decades advising real estate owners in Orange County across tax-deferred exchanges under Section 1031, DSTs, and cost segregation, with continuity from Folkers.
“Your referrals are the lifeblood of our business. We always have time for you, your friends, and your family. Please don't keep us a secret.”
Tom, Max and TimTwo markets. One firm. Palm Desert and Irvine, with clients worldwide.
44751 Village Court, Suite 300 · CA 92260
Private clients, business owners, and families with complex real estate, estate, cross-border, and tax matters, including succession and exit planning when the time is right.
18818 Teller Ave, Suite 275 · CA 92612
Irvine continues the Folkers practice with the broader O'Brien & Panchuk platform behind it. Private clients, operating businesses, professional practices, multi-entity groups, and real-estate owners seeking integrated tax, accounting, advisory, succession, and transaction support.
Written for the owners and families we serve. Each piece should help you see the problem, then start an Assessment if the work fits.
After OBBBA, qualifying stock issued after July 2025 can reach a $15M federal exclusion. The Assessment checks whether the stock actually qualifies under Section 1202.
Read article →A reasonable cause argument that turned a seven-figure penalty into zero.
Read article →How proactive planning and timely filings may reduce FIRPTA withholding in qualifying transactions.
Read article →Explore tax-deferred real-estate strategies following a significant transaction.
Read article →Advisory first. Compliance follows strategy. A predictable monthly engagement based on agreed scope. Designed for substantial business owners, multi-entity families, and private clients who benefit from year-round planning and coordinated execution.
Our advisory relationships focus on opportunities across entity structure, tax elections, accounting, transactions, and long-term planning where proactive involvement can materially improve outcomes.
Year-round access to the professional team. Advisory and compliance on an agreed scope, with a predictable monthly engagement fee. The Assessment is how we determine whether that relationship is the right fit.
We take on a limited number of new advisory relationships, the ones where the model creates meaningful value. Multi-entity owners, real estate investors, professional practices, and families who want a year-round partner, not a once-a-year return.
A conversation, not a pitch. A partner-led conversation to understand your situation and determine whether an ongoing O'Brien & Panchuk relationship is the right fit. The Assessment is $479 and is fully credited toward your first engagement payment if you become a client. Qualifying client and professional referrals may receive a complimentary Assessment.
Start with an AssessmentStart with an Assessment, or contact the front desk. Call or text. The Assessment gives both sides a clear starting point.
Verified outcomes
Founder, Irvine. $12.5M exit. $2.32M QSBS benefit identified under Section 1202.
Case result. Outcomes vary.
Founder, service industry. $30M sale. ESOP plus installment sale under Section 453.
Case result. Outcomes vary.
Executive, coastal California. $1.1M IRS penalty eliminated.
Case result. Outcomes vary.
Property owner, Inland Empire. $5.6M sale into a DST. $1.78M of gain kept off the table.
Case result. Outcomes vary.
Mission-critical operator, Southern California. Walked away from a low LOI after three years of prep. ESOP succession underway.
Case result. Outcomes vary.