G. Michelle Ferreira

San Francisco Managing Shareholder
San Francisco,  CA  U.S.A.
Phone415.655.1305

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Experience & Credentials
 

Practice Areas

  • Tax
  • Trusts & Estates
 
Contact InfoTelephone: 415.655.1305
Fax: 415.358.4883
http://www.gtlaw.com/People/FerreiraGMichelle
 
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 

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
 
Biography

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, Super Lawyers magazine, Northern California Super Lawyers, 2008-2015
•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
•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
•Contributor, IRS Guidance To Cap Potential FBAR Penalties, GT Alert, June 10, 2015
•Co-Author, Still On the Hook: How Calif. Taxpayers Often End Up With Ongoing Tax Liability, GT Alert, November 20, 2014
•Co-Author, The 2014 Voluntary Disclosure Program: Important Changes for the Still Non-Compliant Taxpayer with Foreign Accounts, GT Alert, June 20, 2014
•Co-Author, U.S. Supreme Court Subjects Certain Employment Termination Payments to FICA Tax, GT Alert, April 8, 2014
•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, California Residency Rules Ensnare Unwary Taxpayers, GT Alert, February 4, 2014
•Co-Author, The 2013 GAO Report of the IRS Offshore Voluntary Disclosure Program, International Tax Journal, January-February 2014
•Co-Author, San Francisco Gross Receipts Tax, GT Alert, January 17, 2014
•Co-Author, High Probability of Estate Tax Audit Necessitates Advance Preparation, GT Alert, December 30, 2013
•Co-Author, FTB Unable to Assess Enhanced Promoter Penalties Prior to 2004, GT Alert, December 6, 2013
•Co-Author, New York Court Upholds Retroactive Income Tax Provision for 338(h)(10) Elections, GT Alert, October 26, 2012
•Co-Author, New York Issues Income Tax Ruling on 'Permanent Place of Abode', GT Alert, September 26, 2012
•Co-Author, Non-Resident U.S. Citizens and Green Card Holders Afforded a Streamlined Tax Compliance Program, GT Alert, September 6, 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

Lectures
•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

Associated News & Events

Press Releases

07.09.15 16 Greenberg Traurig Attorneys Included in 2015 Edition of Northern California Super Lawyers & Rising Stars
06.15.15 12 Greenberg Traurig California Attorneys Recognized in 2015 Legal 500 United States Guide
06.08.15 100-Plus Greenberg Traurig Attorneys Recommended in The Legal 500 United States 2015 Guide to Outstanding Lawyers
05.08.15 Greenberg Traurig Shortlisted for 11 Euromoney 'Americas Women in Business Law' Awards
04.06.15 Jeff Palmer Joins Greenberg Traurig's Litigation Practice
10.01.14 Greenberg Traurig Grows Corporate & Securities Practice in San Francisco
08.27.14 23 Greenberg Traurig California Attorneys Recognized in the 2015 Best Lawyers in America
07.30.14 Greenberg Traurig Ranked in 2014 Legal 500 United States Guide
07.15.14 Greenberg Traurig Ranked in 2014 Legal 500 United States Guide
07.08.14 15 Greenberg Traurig Attorneys Included in 2014 Edition of Northern California Super Lawyers & Rising Stars

Alerts

07.16.15 Supreme Court Agrees to Hear Interstate Row About Agency Liability for Aggressive Tax Collection Practices
05.20.15 IRS and DOJ To Build New Tax Fraud Cases Using Data Collected in Voluntary Compliance Programs
11.20.14 Still On the Hook: How Calif. Taxpayers Often End Up With Ongoing Tax Liability
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

Legal Experience

•Trial Attorney, Internal Revenue Service, Office of Chief Counsel

 
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.
 
ISLN911761960
 

Documents by this lawyer on Martindale.com

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Supreme Court Agrees to Hear Interstate Row About Agency Liability for Aggressive Tax Collection Practices
Ed Chansky,Jeremiah Coder,G. Michelle Ferreira,Courtney A. Hopley,Bradley R. Marsh, July 24, 2015
The U.S. Supreme Court granted certiorari of a Nevada Supreme Court decision that imposed tort liability against the California Franchise Tax Board for the agency’s action in conducting a tax audit. The eventual decision by the U.S. Supreme Court will give guidance on the scope of sovereign...

IRS and DOJ To Build New Tax Fraud Cases Using Data Collected in Voluntary Compliance Programs
Jeremiah Coder,Jared E. Dwyer,G. Michelle Ferreira,Scott E. Fink,Courtney A. Hopley, May 29, 2015
On May 8, 2015, the United States Department of Justice announced that it had entered into a “non-prosecution agreement” (NPA) with Swiss bank Vadian Bank AG under the Department of Justice’s (DOJ) Swiss bank program. In its press release announcing the NPA, the DOJ said,...

Still On the Hook: How Calif. Taxpayers Often End Up With Ongoing Tax Liability
Jeremiah Coder,G. Michelle Ferreira, January 22, 2015
It is surprising how often a California taxpayer receives a notice from the Franchise Tax Board (FTB) asserting an unpaid tax liability years after the general statute of limitations period has passed.
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Office Information

G. Michelle Ferreira

4 Embarcadero Center, Suite 3000
San FranciscoCA 94111-5983




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