Shail P. Shah

Experience: Representative Matters: Representing the National Taxpayers Union (NTU) before the Superior Court of California, challenging a portion of California Senate Bill 167 as unconstitutional under the Due Process Clauses of the United States and California Constitutions.; Representing a Texas physician before the California Court of Appeal, challenging the FTB's taxation of the physician's out-of-state income.; Secured over $50 million from the California FTB for a Fortune 25 client by resolving over almost 10 years of audits by identifying refund opportunities through settlement and maximizing overpayment interest for the client.; Settled a complex tax shelter case with the California FTB despite strong precedent against the client's case.; Successfully defended numerous high-net-worth clients against California residency audits.; Negotiated settlements for numerous Fortune 50 companies in response to local tax assessments by the City of San Francisco and the City of Los Angeles.; Assisted a large energy client with quickly filing a complaint in California Superior Court to secure a full refund for overpaid sales and use taxes.; Navigated numerous clients through California's complex voluntary disclosure program both at the FTB and CDTFA.; Assisted M&A clients on California tax issues both on buy-side and sell-side transactions.; Represented numerous clients in front of the FTB's protest and settlement units, the CDTFA's appeals board, and the OTA.; Fully abated discretionary penalties imposed by the FTB by arguing the FTB failed to follow specific procedural steps required by law.; Formulated taxpayer-friendly methodologies for foreign investment interest offset (FIIO), business income determinations from treasury investments, and unique receipts for sales factor purposes.; The above representations were handled by Mr. Shah prior to his joining Greenberg Traurig, LLP.; Government Experience: Tax Counsel III, California Franchise Tax Board, 2010-2012; Previous Experience: Tax Manager, EY, 2007-2010; Associate and Managing Director, Andersen Tax, 2006-2007; 2012-2018;