Michelle Ferreira is Senior Vice President and Co-Managing Shareholder of the San Francisco and Silicon Valley offices 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 California Department of Tax and Fee Administration , 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 23 reported decisions in the U.S. Tax Court on issues such as split dollar life insurance, 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.
- 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
- Estate and gift tax controversies
- Valuation disputes
- Criminal tax investigations and litigation
- Tax penalties
- Tax shelter investigations, audit and litigation
- U.S. and foreign information document requests
- Tax procedure
- Tax shelter promoter audits and investigations