G. Michelle Ferreira

San Francisco Managing Shareholder
San Francisco,  CA  U.S.A.

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Experience & Credentials

Practice Areas

  • Tax
  • Trusts & Estates
Contact InfoTelephone: 415.655.1305
Fax: 415.358.4883
University University of California at Davis, B.S., 1990
Law SchoolSanta Clara University School of Law, J.D., 1995
Admitted1995, California; U.S. District Court for the Northern District of California; U.S. Tax Court; Supreme Court of California

Professional & Community Involvement
•Adjunct Professor, Golden Gate University School of Tax
•Member, American Bar Association, Taxation Section
•Member, National Association of State Bar, Tax Section, Executive Committee
•Member, San Francisco Estate Planning Council
•Member, San Francisco Tax Club
•Member, California State Bar, Taxation Section, 2006-Present
•Chair, 2009-2010
•Member, Executive Committee, 2006-2010

LanguagesSpanish, Conversational
BornBaton Rouge, Louisiana, 1967

G. Michelle Ferreira 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 was the former Chair of the Executive Committee of the Taxation Section of the California State Bar in 2009-2010. She frequently speaks on topics of tax controversy and tax procedure before professional associations for both lawyers and accountants, and she was an Adjunct Professor for the Master's in Taxation Program at Golden Gate University in San Francisco.

Outside of the office, Michelle is involved in a wide array of tax professional organizations and has established key relationships with IRS and state taxing agency executives. She is nationally recognized for her audit and litigation experience in estate and gift tax disputes with the IRS, especially cases involving challenges to family limited partnerships and valuation disputes.

Areas of Concentration
•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

Awards & Recognition
•Listed, The Best Lawyers in America, Litigation and Controversy - Tax; Tax Law, 2011-2015
•Listed, The Legal 500 United States, Tax Controversy, 2012-2015
•Listed, San Francisco Business Times, The Most Influential Women in the Bay Area, 2014
•Recipient, Best in Tax Dispute Resolution, American Women in Business Law Awards, IFLR/Euromoney, 2014
•Listed, Super Lawyers magazine, Northern California Super Lawyers, 2008-2014
•Named, Daily Journal, one of the 10 Emerging Law Firm Leaders in California, 2013
•Recipient, V. Judsen Klein Award, State Bar of California, Taxation Section, 2012
•Nominee, 2010 Tax Person of the Year, Tax Analysts, January 2011
•Recipient, Certificate of Appreciation, IRS Small Business/Self-Employed Division, May 2002
•Recipient, Performance Award, IRS Small Business/Self-Employed Division, Fall 2001
•Recipient, Special Act Award, for litigation of Estate of Schauerhamer v. Commissioner, T.C. Memo 1997-242, December 1997

Articles, Publications, & Lectures

Articles & Publications
•Quoted, IRS May Turn to Hostile Congress to Regulate Tax Preparers, Law360, February 13, 2014
•Quoted, Appeals Court Affirms Loving, Disallowing Preparer Requirements, Tax Analysts, February 12, 2014
•Quoted, Tax Preparers Defeat IRS in Appeals Court Ruling on Licensing Scheme, Accounting Today, February 11, 2014
•Co-Author, The 2013 GAO Report of the IRS Offshore Voluntary Disclosure Program, International Tax Journal, January-February 2014
•Quoted, IRS Amnesty Puts Calif. Residents in a Bind, The Recorder, Law.com, January 24, 2012
•Quoted, Audits of Wealthy Taxpayers Pose Challenges, Practitioners Say, Tax Analysts, September 29, 2011
•Quoted, Background Checks, Vague Definition of Tax Preparers Still Worry Practitioners, The Bureau of National Affairs, Inc, Daily Tax Report, January 13, 2011

•Panelist, Practice Tips and War Stories from Tax Court, The State Bar of California's First Annual Young Tax Lawyers Conference, San Francisco, CA, January 28, 2014
•Panelist, Practical Investigative Techniques for Lawyers, ABA 30th Annual National Institute on Criminal Tax Fraud and Third National Institute on Tax Controversy, Las Vegas, NV, December 12, 2013
•Panelist, Federal Procedural Roundtable, 2013 Annual Meeting of the California Tax Bar & The California Tax Policy Conference, San Jose, CA, November 9, 2013
•Panelist, A Critical Look at the IRS Offshore Voluntary Disclosure Programs - 5 years Out, 2013 USD-Procopio International Tax Institute, San Diego, CA, October 24, 2013
•Panelist, Got Penalties? The Policy Behind Penalties & the Reasonable Cause Standard, 2013 Annual Tax Controversy Institute UCLA Extension, Beverly Hills, CA, October 22, 2013
•Panelist, It's Not My Fault! The Scope of the Reasonable Cause and Good Faith Exception to Tax Penalties, 5th Annual Tax Controversy Forum, New York, NY, June 7, 2013
•Panelist, Facing the IRS: What Happens When a Client Gets 'The Notice?' Tax Talk Today Webinar, November 20, 2012
•Panel Moderator, Federal Procedural Roundtable and Penalties: Reasonable Cause and Otherwise [ETHICS], California Tax Bar & California Tax Policy Conference, San Diego, CA, November 3, 2012
•Speaker, FATCA and OVDP and Offshore Reporting, National Association of State Bar Tax Section's Annual Meeting, San Francisco, CA, October 26, 2012

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05.02.13 Greenberg Traurig Brings Together High-Level Women for Thought Leadership Conference at its 6th Annual Women's Business Forum

06.20.14 The 2014 Voluntary Disclosure Program: Important Changes for the Still Non-Compliant Taxpayer with Foreign Accounts
04.08.14 U.S. Supreme Court Subjects Certain Employment Termination Payments to FICA Tax
02.04.14 California Residency Rules Ensnare Unwary Taxpayers
01.17.14 San Francisco Gross Receipts Tax
12.30.13 High Probability of Estate Tax Audit Necessitates Advance Preparation
12.06.13 FTB Unable to Assess Enhanced Promoter Penalties Prior to 2004
10.26.12 New York Court Upholds Retroactive Income Tax Provision for 338(h)(10) Elections
09.26.12 New York Issues Income Tax Ruling on 'Permanent Place of Abode'
09.06.12 Non-Resident U.S. Citizens and Green Card Holders Afforded a Streamlined Tax Compliance Program
06.29.12 IRS Releases New Frequently Asked Questions for its Offshore Voluntary Disclosure Program and Announces Procedures to Assist U.S. Citizens Living Abroad

Reported CasesSignificant Representations Michelle has 17 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.

Documents by this lawyer on Martindale.com

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The 2014 Voluntary Disclosure Program: Important Changes for the Still Non-Compliant Taxpayer with Foreign Accounts
Seth J. Entin,G. Michelle Ferreira,Courtney A. Hopley, July 8, 2014
On June 18, 2014, the Commissioner of the Internal Revenue Service (IRS), John Koskinen, announced significant changes to the IRS’s offshore voluntary disclosure program (referred to as the “2014 OVDP”). The changes to the program are described in this Alert. The changes are...

U.S. Supreme Court Subjects Certain Employment Termination Payments to FICA Tax
Jeremiah Coder,G. Michelle Ferreira,Scott E. Fink,Courtney A. Hopley,Barbara T. Kaplan, April 14, 2014
Hopes that certain severance payments paid by companies to terminated employees could escape application of the Federal Insurance Contributions Act (FICA) tax were dashed when a unanimous U.S. Sreme Court ruled on March 25th that such payments, when not tied to state unemployment benefits, were...

California Residency Rules Ensnare Unwary Taxpayers
Jeremiah Coder,G. Michelle Ferreira,Courtney A. Hopley,Bradley R. Marsh,Alejandro Ruiz, February 7, 2014
California’s reputation as hard-nosed when it comes to finding ways to creatively assert tax liability is well-justified. Nonresidents frequently find themselves in the California Franchise Tax Board’s (FTB) cross-hairs as susceptible targets for asserted tax liability based on a long...

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Office Information

G. Michelle Ferreira

4 Embarcadero Center, Suite 3000
San FranciscoCA 94111-5983


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