G. Michelle Ferreira

Michelle Ferreira is Executive Vice President, Co-Chair of the Global Tax Practice, and Co-Managing Shareholder of the firm’s San Francisco and Silicon Valley offices. She advises individuals, partnerships, estates, and corporations in complex tax disputes with the Internal Revenue Service and state and local tax authorities, including the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, and county assessment appeals boards.

Drawing on her prior experience as a tax litigator with the Internal Revenue Service, Michelle brings a distinctive and strategic perspective to sensitive and high-stakes tax and penalty matters. She represents clients at every stage of a tax controversy—audits, collections, appeals, and litigation—before the IRS and state and local taxing authorities.

Michelle has 23 reported decisions in the U.S. Tax Court addressing a wide range of sophisticated tax issues, including split-dollar life insurance, unreported income, family limited partnerships, gift tax and valuation disputes, civil and criminal tax fraud, penalty assessments, statute of limitations defenses, valuation disputes and discounts for lack of control and marketability, tax shelters, hobby losses, complex real estate and structured transactions, Bipartisan Budget Act of 2015 partnership audits, microcaptive insurance companies, conservation easements, Employee Retention Credit disputes and substantiation of business expenses.