Image: Lucas M. Rachuba

Lucas M. Rachuba

Partner, Tax Department


Lucas Rachuba is a partner in the Tax practice based in the San Francisco and Century City offices. Lucas focuses on private equity and public company M&A, credit funds, hedge funds, venture capital, and real estate transactions. His clients include private equity firms, portfolio companies, public companies, and stand-alone fund clients. He works with private equity principals, boards of directors, and members of senior management. He also advises on various topics related to transaction and fund structuring, including on international issues, taxation of carried interests, QSBS and tax elements of compensation structuring.


  • J.D., Harvard Law School, 1999, Magna Cum Laude
  • A.B., Dartmouth College, 1996, Summa Cum Laude


Mr. Rachuba’s recent client successes include advising:

  • A New York-based private equity fund on its acquisition of an Australian mortgage business.
  • A San Francisco-based private equity fund on the recapitalization and IPO of its portfolio company.
  • A Los-Angeles based private equity fund on multiple international acquisitions.
  • Los Angeles and New York-based publicly-traded partnerships on converting to corporations post-2017 tax reform.
  • Various private equity and hedge fund professionals on solutions to the new “3 year carry” capital gain rules.
  • A Los Angeles-based credit fund manager on the tax implications of setting up a Japanese KK subadvisor.
  • Various industry professionals on self-employment tax strategies.
  • An energy fund on Latin American power purchase agreement investments.
  • A Singapore sovereign wealth fund on investments in loan origination and life settlement platforms.
  • A sovereign wealth fund on the implications of 2017 tax reform for its MNC investee companies, such as airlines and telecoms.
  • A U.S. credit fund on airplane leasing transactions in Ireland.
  • Clients on the U.S. tax aspects of structuring an India-focused VC/PE fund.
  • A U.S. hedge fund on a restructuring of an Atlanta-based real estate investment.
  • A U.S. credit fund on setting up an Irish treaty platform for its direct lending investments.
  • A Canadian sovereign wealth fund on an acquisition of multiple U.S. partnerships and corporations from a San Francisco private equity fund.
  • A Hong Kong-based asset manager on U.S. tax deferral techniques/platforms.
  • A credit fund on the acquisition of multiple blocker entities from a U.S. private equity fund.
  • Clients on the availability of foreign tax credits for a withholding tax imposed on a series of VC funds selling an India investment to a multinational retailer.
  • A hedge fund on the acquisition of Latin American receivables.
  • A Middle Eastern sovereign fund on investment in a Brazil clean energy platform.


Engagement & Publications

  • Speaker on UBTI issues, Stanford Management Company annual legal counsel conference, Palo Alto
  • Speaker, Wells Fargo Tax Reform panel for hedge funds, San Francisco
  • Speaker, BofA Merrill Lynch hedge fund tax roundtable, San Francisco
  • Speaker, PEI Private Equity Conference, San Francisco
  • Speaker, American Bar Association Tax Committee meeting, San Francisco
  • Speaker, EY Alternative Funds Symposia, San Francisco and Los Angeles
  • Speaker, EY International Tax Conferences, New York and Singapore

Practice Areas





California Bar

New York Bar


Harvard Law School, J.D. 1999

Dartmouth College, A.B. 1996

Get In Touch With Us

Contact Us