Michelle Ferreira

Tax

Private Wealth Services

Audits, Litigation & Criminal Tax Defense

State & Local Tax (SALT)

Cross-Border Tax Planning

State & Federal Tax Controversies

Equine Industry Group

Michelle Ferreira is Co-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 21 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

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.

Listed, Chambers USA Guide, 2017-2022

J.D., Santa Clara University School of Law, 1995

B.S., University of California at Davis, 1990