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
Memberships State Bar of California (Chair, Executive Committee, Tax Section, 2009-2010; Member, Executive Committee, Taxation Section, 2006- 2008); American Bar Association (Member, Taxation Section).

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

Professional & Community Involvement

· Member, American Bar Association, Taxation Section

· Member, California State Bar, Taxation Section

· Member, Executive Committee, National Association of State Bar Tax Sections

· Member, San Francisco Estate Planning Council

· Member, San Francisco Tax Club

· Chair, Executive Committee, Tax Section, California State Bar, 2009-2010

· Member, Executive Committee, Taxation Section, 2006-2008

Awards & Recognition

· Listed, The Best Lawyers in America, Litigation and Controversy - Tax; Tax Law, 2011-2014

· Named, Daily Journal, One of the "10 Emerging Law Firm Leaders in California," 2013

· Listed, The Legal 500 United States, 2012-2013

· Listed, Super Lawyers magazine, Northern California Super Lawyers, 2008-2013

· 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

Professional Experience

Significant Representations

Michelle has 17 reported decisions in the United States 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.

Other Experience

· Trial Attorney for the Office of Chief Counsel, Internal Revenue Service

· Adjunct Professor, Golden Gate University School of Tax

Publications & Presentations

Articles, Lectures & Publications

· 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]," Annual Meeting of the 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, California, October 26, 2012

· 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


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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