Greenberg Traurig LLP

Tax

Co-Managing Shareholder

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and 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 has 18 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.

ConcentrationsTax compliance adviceCivil tax disputes, including audits, appeals and collection matters Offshore income tax disputes, foreign income, bank and asset reporting and related penalty assessmentsComplex tax litigationCriminal tax investigations and litigationTax penaltiesTax shelter investigations, audit and litigationTaxing agencies’ information document requestsTax procedureTax shelter promoter audits and investigationsEstate and gift tax disputes

CapabilitiesTax Private Wealth Services Audits, Litigation & Criminal Tax Defense State & Local Tax (SALT) Cross-Border Tax Planning Fiduciary Litigation State & Federal Tax Controversies

Admission to PracticeCaliforniaSupreme Court of CaliforniaU.S. District Court for the Northern District of CaliforniaU.S. District Court for the Central District of CaliforniaU.S. Tax Court

EnglishSpanish

J.D., Santa Clara University School of Law, 1995 B.S., University of California at Davis, 1990