Profile
Shail Shah is a skilled multistate tax attorney with over 18 years of experience guiding clients through complex state and local tax (SALT) matters, with a particular emphasis on California and local tax issues. His clients include Fortune 25 corporations and high-net-worth individuals who rely on his strategic counsel for navigating the intricacies of state tax planning, compliance, and controversy.
Shail focuses on California tax planning and representation before key agencies, including the California Franchise Tax Board (FTB), California Department of Tax and Fee Administration (CDTFA), Office of Tax Appeals (OTA), Board of Equalization (BOE), and both administrative and judicial forums at the state and local levels. Leveraging his background as a former attorney at the FTB, Shail is adept at turning audits and assessments into opportunities for tax savings and refund claims, and he is highly sought after for both proactive residency planning and robust audit defense.
In addition to his deep California experience, Shail regularly advises on local tax issues such as the San Francisco Gross Receipts Tax, the Los Angeles Business Tax, and the Oakland Business Tax.
Shail also advises large companies on complicated multistate tax issues, helping clients address the challenges of doing business across multiple jurisdictions and seeking to ensure compliance with a constantly evolving tax landscape.
A recognized thought leader, Shail is a frequent speaker on SALT topics at national and regional conferences, including the Council On State Taxation (COST), Tax Executives Institute (TEI), California Lawyers Association (CLA), and others. He currently serves as the incoming chair of the Executive Committee of the Tax Section for CLA.
Capabilities
Experience
- Representing the National Taxpayers Union (NTU) before the Superior Court of California, challenging a portion of California Senate Bill 167 as unconstitutional under the Due Process Clauses of the United States and California Constitutions.
- Representing a Texas physician before the California Court of Appeal, challenging the FTB’s taxation of the physician’s out-of-state income.
- Secured over $50 million from the California FTB for a Fortune 25 client by resolving over almost 10 years of audits by identifying refund opportunities through settlement and maximizing overpayment interest for the client.°
- Settled a complex tax shelter case with the California FTB despite strong precedent against the client’s case.°
- Successfully defended numerous high-net-worth clients against California residency audits.
- Negotiated settlements for numerous Fortune 50 companies in response to local tax assessments by the City of San Francisco and the City of Los Angeles.
- Assisted a large energy client with quickly filing a complaint in California Superior Court to secure a full refund for overpaid sales and use taxes.°
- Navigated numerous clients through California’s complex voluntary disclosure program both at the FTB and CDTFA.°
- Assisted M&A clients on California tax issues both on buy-side and sell-side transactions.°
- Represented numerous clients in front of the FTB’s protest and settlement units, the CDTFA’s appeals board, and the OTA.°
- Fully abated discretionary penalties imposed by the FTB by arguing the FTB failed to follow specific procedural steps required by law.°
- Formulated taxpayer-friendly methodologies for foreign investment interest offset (FIIO), business income determinations from treasury investments, and unique receipts for sales factor purposes.°
°The above representations were handled by Mr. Shah prior to his joining Greenberg Traurig, LLP.
- Tax Counsel III, California Franchise Tax Board, 2010-2012
- Tax Manager, EY, 2007-2010
- Associate and Managing Director, Andersen Tax, 2006-2007; 2012-2018
Recognition & Leadership
- Listed, The Best Lawyers in America, 2025
- Tax Law
- Litigation and Controversy - Tax
- Member, Law360 Editorial Advisory Board, Tax Authority State & Local, 2025
- Chair-Elect, Executive Committee, California Lawyers Association (CLA), Taxation Section, 2026-2027
- Executive Committee Member, California Lawyers Association (CLA), Taxation Section
- Board Member, Advisory Board, California Office of Tax Appeals
- Board Member and Executive Committee Member, Justice and Diversity Center, Bar Association of San Francisco
- Member, State Bar of California
Credentials
- LL.M., Taxation, University of San Diego School of Law
- J.D., University of San Diego School of Law
- B.A., University of California, Los Angeles
- California
- Gujarati, Conversational