G. Michelle Ferreira

Michelle Ferreira is Executive Vice President, Co-Chair of the Global Tax Practice, and Co-Managing Shareholder of the firm’s San Francisco and Silicon Valley offices. She advises individuals, partnerships, estates, and corporations in complex tax disputes with the Internal Revenue Service and state and local tax authorities, including the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, and county assessment appeals boards.

Drawing on her prior experience as a tax litigator with the Internal Revenue Service, Michelle brings a distinctive and strategic perspective to sensitive and high-stakes tax and penalty matters. She represents clients at every stage of a tax controversy-audits, collections, appeals, and litigation-before the IRS and state and local taxing authorities.

Michelle has 23 reported decisions in the U.S. Tax Court addressing a wide range of sophisticated tax issues, including split-dollar life insurance, unreported income, family limited partnerships, gift tax and valuation disputes, civil and criminal tax fraud, penalty assessments, statute of limitations defenses, valuation disputes and discounts for lack of control and marketability, tax shelters, hobby losses, complex real estate and structured transactions, Bipartisan Budget Act of 2015 partnership audits, microcaptive insurance companies, conservation easements, Employee Retention Credit disputes and substantiation of business expenses.

Concentrations

•Tax compliance and advisory matters
•Civil tax disputes, including audits, appeals, and collections
•Offshore penalty and foreign income tax controversies, including reporting obligations and penalty assessments
•Complex tax litigation
•Franchise Tax Board and California Tax and Fee Administration audits, protests and Office of Tax Appeal litigation
•California state residency audits and advice
•Estate and gift tax disputes
•Valuation controversies
•Criminal tax investigations and litigation
•Tax penalties, federal and state
•Tax shelter audits, investigations, and litigation
•U.S. and foreign information document requests
•Tax procedure
•Tax shelter promoter audits and investigations

Recognition & Leadership

Awards & Accolades

•Shortlisted, Euromoney, 'Women in Business Awards - Tax Dispute Resolution Lawyer of the Year, ' 2024
•Listed, The Best Lawyers in America, Litigation and Controversy - Tax; Tax Law, 2011-2026
•'Lawyer of the Year,' Tax Law, San Francisco, 2026
•'Lawyer of the Year,' Litigation and Controversy - Tax, San Francisco, 2023
•Selected, International Tax Review, World Tax Leader - Americas, 'Highly Regarded,' 2023 and 2025 and 2026
•Women in Tax Leader, 2025-2026
•Listed, Chambers USA Guide, 2017-2025
•Listed, Lawdragon, '500 Leading Global Tax Lawyers,' 2025
•Listed, The Legal 500 United States
•Tax - US Taxes: Contentious, 2021 and 2025
•Tax Controversy, 2012-2015, 2018-2020
•Winner, Collaborative Leadership Award, Women, Influence & Power in Law Awards, Corporate Counsel, 2023
•Listed, Chambers USA Guide, 'Recognized Practitioner,' 2016
•fellow of the American College of Tax Counsel
•Listed, Super Lawyers magazine, Northern California Super Lawyers, 2008-2025
•Listed, Euromoney's Expert Guides: Women in Business Law, 'Guide to the World's Leading Women in Business Law,' 2017 and 2021-2022
•Selected, Profiles in Diversity Journal, 'Woman Worth Watching,' 2019
•Shortlisted, Euromoney Legal Media Group’s Americas Women in Business Law Awards, 'Best in Tax Dispute Resolution,' 2016-2018
•Winner, 'Best in Tax Dispute Resolution,' 2018
•Listed, San Francisco Business Times, Forever Influential Honor Roll,' 2016 and 2017
•Listed, 'The Most Influential Women in the Bay Area,' 2014
•Recipient, 'Best in Tax Dispute Resolution,' American Women in Business Law Awards, IFLR/Euromoney, 2014
•Recipient, V. Judsen Klein Award, State Bar of California, Taxation Section, 2012
•Recipient, Performance Award, IRS Small Business/Self-Employed Division, Fall 2001