G. Michelle Ferreira

G. Michelle Ferreira

Shareholder

G. Michelle Ferreira is Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

Concentrations

  • Tax compliance advice
  • Civil tax disputes, including audits, appeals and collection matters 
  • Offshore income tax disputes, foreign income, bank and asset reporting and related penalty assessments
  • Complex tax litigation
  • Criminal tax investigations and litigation
  • Tax penalties
  • Tax shelter investigations, audit and litigation
  • Taxing agencies’ information document requests
  • Tax procedure
  • Tax shelter promoter audits and investigations
  • Estate and gift tax disputes
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Capabilities

Experience

  • Trial Attorney, Internal Revenue Service, Office of Chief Counsel, 1995-2003

Recognition & Leadership

  • Listed, Euromoney's Expert Guides: Women in Business Law, "Guide to the World's Leading Women in Business Law," 2017
  • Fellow of the American College of Tax Counsel
  • Listed, Chambers USA Guide, 2017
  • Listed, The Best Lawyers in America, Litigation and Controversy - Tax; Tax Law, 2011-2018
  • Listed, Chambers USA Guide, "Recognized Practitioner," 2016
  • Shortlisted, Euromoney Legal Media Group’s Americas Women in Business Law Awards, "Best in Tax Dispute Resolution," 2016 and 2017
  • Listed, The Legal 500 United States, Tax Controversy, 2012-2015
  • Listed, Super Lawyers magazine, Northern California Super Lawyers, 2008-2017
  • Listed, San Francisco Business Times, Forever Influential Honor Roll," 2016 and 2017
    • Listed, "The Most Influential Women in the Bay Area," 2014
  • Recipient, "Best in Tax Dispute Resolution," American Women in Business Law Awards, IFLR/Euromoney, 2014
  • Recipient, V. Judsen Klein Award, State Bar of California, Taxation Section, 2012
  • Recipient, Performance Award, IRS Small Business/Self-Employed Division, Fall 2001
  • Member, American Bar Association, Taxation Section
  • Member, San Francisco Tax Club
  • Member, California State Bar, Taxation Section, 2006-Present
    • Chair, 2009-2010
    • Member, Executive Committee, 2006-2010
  • Adjunct Professor, Golden Gate University School of Tax

Credentials

Education
  • J.D., Santa Clara University School of Law, 1995
  • B.S., University of California at Davis, 1990
Admissions
  • California
  • Supreme Court of California
  • U.S. District Court for the Northern District of California
  • U.S. District Court for the Central District of California
  • U.S. Tax Court
Languages
  • Spanish, Conversational