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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.

On Sept. 13, 2021, the U.S. House Ways and Means Committee announced a proposal to limit charitable deductions for conservation easement contributions made by partnerships and other passthrough entities. The
Continue Reading House Proposal Targets Charitable Deductions for Conservation Easements by Passthrough Entities

In February 2020, the IRS announced that it would step up efforts to contact high-income taxpayers (defined as earning $100,000 or more per year), who in prior years have failed
Continue Reading The IRS Announced a New Non-Filer Initiative Over a Year Ago – Now We See the Enforcement

Taxpayers that have engaged in cryptocurrency transactions should be aware that the Internal Revenue Service is seeking customer records from cryptocurrency exchanges. The Department of Justice recently filed petitions in
Continue Reading IRS Actively Seeking Information Regarding Cryptocurrency Via John Doe Summonses

On August 10, 2020, the San Francisco Superior Court granted the State of California a preliminary injunction requiring Uber and Lyft to reclassify their drivers as employees.  People of the


Continue Reading Court Rules that Uber and Lyft Cannot Treat California Drivers as Independent Contractors

On Sept. 18, 2019, Governor Gavin Newsom signed Assembly Bill No. 5 (AB 5) into law in California. The landmark legislation, which came into effect Jan. 1, 2020, promises to
Continue Reading AB 5, California’s Gig-Work Law, Could Mean Inconsistent Federal and State Tax Treatment for Workers

While the IRS has been cracking down on syndicated conservation easements for over ten years, earlier this year Chuck Rettig, the Commissioner of the IRS, announced several campaign areas upon
Continue Reading Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases

Campaign for Compliance

Last year the IRS announced a new campaign to target “Withholding and International Individual Compliance” regarding Forms 1042 and 1042-S. Those who make payments of certain U.S.-source
Continue Reading Now Is the Time to Consider Voluntary Disclosure: Advancement of the IRS Campaign on Withholding Tax Noncompliance for Forms 1042, 1042-S