Tax litigation matters compel individuals or organizations to incur higher costs. The expenditures are rising and never-ending. Shelling out money at this level isn’t really worth it. To handle these matters, ideally, we need tax controversy professionals who have the right knowledge and expertise to bring the tax regime back to normal. These professionals not only deal with the rules and regulations, but they also help us make sense of those rules. Years of study and practice enable them to guide their clients to manage those procedures ideally. One such similar leader is G. Michelle Ferreira, Executive Vice President, Co-Chair, Global Tax Practice at Greenberg Traurig, LLP. She has decades of expertise as she handles the organization’s Silicon Valley office and the firm’s Global Tax Practice. She also maintains ease with the firm’s recruitment, business development, and strategic growth.
Factual Works
Michelle shoulders the dual responsibility of Executive Vice President and Co-Chair of the Global Tax Practice. These roles require oversight of the global tax department and law firm strategy while ensuring client satisfaction. At an institutional level, she molds the strategic direction of the global tax practice and oversees Greenberg Traurig’s (GT) California offices as regional operating shareholder. She is expected to forecast regulatory shifts, market trends, and client needs. She also ensures that the teams are performing efficiently.
Law firm strategy isn’t something that just lives in a handbook; it’s a constant, living balance. She looks at the legal world through two lenses: a big picture view that stays ahead of a shifting global market, and a much more personal view that focuses on what a client actually needs in the moment.
She brings that same energy to her tax controversy work. Whether she’s defending a case in U.S. Tax Court, navigating a state-level dispute, or handling a sensitive audit, she knows that legal expertise is only half the battle. The other half is staying hyper-aware of the political climate and changing audit priorities that could affect her clients’ futures.
Ultimately, her philosophy is simple: great results come from combining broad strategy with an obsessive attention to detail. She wants her clients to feel like more than just a case number; she wants them to feel steady and supported from the first meeting to the final resolution.
Wisdom Counts
When Michelle looks at today’s enforcement trends, she’s drawing on a unique vantage point from her time at the IRS Office of Chief Counsel. Litigating for the Commissioner wasn’t just a job; it was a front-row seat to the agency’s inner workings. She saw firsthand how the IRS selects its battles, builds its cases, and navigates the long road from the first audit letter to a final resolution. It gave her a grounded understanding of how the agency manages to stay focused on its goals despite limited resources and constant political noise.
Through that experience, Michelle realized that enforcement isn’t just a mechanical application of rules. It’s a human process driven by policy shifts, public sentiment, and very real practical hurdles. Having sat on both sides of the table, she offers her clients a perspective that is as balanced as it is sharp. She can anticipate what will catch an agent’s eye and understands the internal logic that drives the IRS’s biggest decisions.
She shares, “I advise clients to anticipate the IRS’s audit targets and to navigate the process proactively, drawing on my knowledge of how enforcement decisions have been historically made and executed.”
She also knows that, in the heat of a dispute, the small things are actually the big things. Whether it’s the strength of a single document or a well-timed procedural defense, the details are what win cases. Michelle’s goal is to keep her clients one step ahead, predicting where the spotlight might land and walking them through the process with a steady hand and a clear sense of direction.
Aligning Strategies Well
Michelle stresses that enforcement priorities used to target emerging risk, such as cryptocurrency reporting, foreign asset disclosures, and large partnership structures, where compliance gaps were perceived. Michelle gets why taxpayers are feeling uneasy right now. Between a shrinking IRS workforce and the wild west of crypto and digital asset rules, the path forward isn’t always clear. When case law is thin, and the official signals keep shifting, it’s frustrating to try to play by the rules. Michelle doesn’t just cite the law; she recognizes human frustration. She sits down with her clients to cut through the noise, offering the kind of steady, practical advice that turns total uncertainty into a clear, confident plan of action.
Before the 2025 budget cuts and the resulting dip in the IRS workforce, everyone knew where the lines were drawn, especially with things like foreign assets, crypto, and large partnerships. Michelle knows that even though the headlines have changed, the underlying laws haven’t. The rules are still there, even if the police on the beat look a little different these days.
In this quieter but more unpredictable environment, Michelle understands that clients aren’t just looking for a lawyer, they’re looking for a compass. When the signals from the government feel fuzzy, it’s easy to feel a false sense of security. Michelle is there to remind her clients that while enforcement might feel less aggressive right now, the risks of a mistake-like heavy fines or even criminal exposure- are just as sharp as ever.
She takes the guesswork out of the equation. By offering clear, honest guidance, Michelle helps her clients find that middle ground: staying fully compliant and protected, without the stress of wondering what if the wind shifts again.
She adds, “In this environment of lack of guidance or tax enforcement, sophisticated tax clients need my advice more than ever before.”
California’s Tax Policy
Michelle believes that California’s tax environment is uniquely challenging. Especially, the fiscal policy revolves around budgetary pressures and income inequality. The state holds a robust approach to income, residency, and sales tax disputes. It is now intersecting with proposed wealth-based initiatives, such as wealth taxes or exit taxes targeting California’s high-net-worth individuals.
There prevails a significant tension between California’s fiscal objectives and taxpayer residency in California. As policymakers and unions propose new health and exit taxes, individuals and businesses are increasingly scrutinizing their residency status and are relocating to more tax-friendly states. The Billionaire Tax Act of 2026 has caused a lot of genuine local anxiety. Because it’s a ballot initiative to amend the state constitution, it feels different, more permanent, and less negotiable. Michelle has seen how even the talk of a 5% wealth tax makes California’s highest earners pause. It’s not just about the money; it’s about whether they still see a future here. She understands that if these individuals leave, they don’t just take their tax dollars; they take the businesses, jobs, and networks that have helped the state thrive.
Michelle sees a similar story playing out with aggressive sales tax enforcement. While the goal is to fund vital services like schools and healthcare, she’s watched how it can backfire. When the environment feels more like a penalty than a partnership, businesses eventually look for the exit. She’s already seen companies that once called California home move elsewhere, and with them goes the innovation that defines our state.
For Michelle, this isn’t just a series of technical tax hurdles; it’s a question of confidence. She believes California needs a balanced way to fund its future without making people feel like they’re being pushed out.
She adds, “Navigating these complexities demands not only technical expertise, but also a thorough understanding of how government fiscal and policy priorities motivate resident businesses and individuals’ desire to remain in California.”
Striking Own Balance
Recently, Michelle has observed a distinct shift in the balance between taxpayer rights and governmental enforcement power. These are largely driven by decreased funding for the IRS, limited technological capabilities, and heightened political attention. The government’s enforcement tools have become limited, particularly in staffing, leadership, audit priorities, published guidance, and technology resources. At the same time, administrative law developments in prior years led to an evolving economic policy to aggressively pursue civil and criminal penalties and target tax shelter transactions. This robust focus on auditing the wealthy and enforcing tax shelters has been scaled back considerably in the last year.
While taxpayer protections, such as procedural safeguards, appeal rights, and statutory defenses, remain firmly embedded, the pace and complexity of enforcement have decreased. This has left practitioners and taxpayers to wonder what the agency’s audit priorities and enforcement direction are. In the prevailing environment, tax controversy practitioners like Michelle are left without information from the IRS about what tax positions to take and what audit risk is prevalent for clients. This has placed greater pressure on taxpayers to substantiate positions, comply with information requests, and proactively defend their interests, essentially in a vacuum.
She shares, “I believe the pendulum has shifted towards less government enforcement power. However, this enforcement direction can shift again with new political powers who will oversee the IRS in the future.”
Open to Learning
Michelle manages recruitment, strategic growth, and shareholder compensation within the global law firm. She highlights that the tax controversy practice, which is institutionally resilient, does not depend only on technical proficiency. Structurally, it cultivates multidisciplinary experience, invests in technological innovation, and fosters a culture of collaboration and adaptability. Recruitment is strategic, emphasizing diversity of experience, backgrounds, markets, and skills.
Institutionally resilient teams prioritize ongoing education, anticipate regulatory and market shifts, and proactively develop strategies for emerging legal demands such as digital assets, wealth taxes, and cross-border enforcement. The team deploys data analytics, automation, and AI into daily business that brings in precision and efficiency. Client engagement is holistic and anticipatory, not just reactive. Compensation and growth are tied to knowledge sharing, innovation, and client outcomes.
She shares, “A successful law firm rewards individual and collaborative success of its lawyers while also constantly adjusting to ever-changing market demands, priorities in clients, and evolving legal practices.”
The organization’s success is in its ability to adapt, innovate, and lead to help ensure the practices and firm are positioned to navigate complex legal matters today and to seize market opportunities in the future.
Principled Tax Controversy Practice
Michelle shares that a lawyer who is interested in resolving tax disputes efficiently distinguishes themselves through strategic foresight, clear communication, and a deep understanding. This can be done through both substantive law and procedural nuance. Efficient resolution stems from anticipating the concerns of tax authorities, providing thorough and well-organized documentation, and addressing issues proactively before they become contentious.
According to her, the most successful and powerful tax controversy lawyers are proficient at building credibility with state and federal taxing agencies. It fosters constructive dialogue and identifies common ground in audits and appeals.
She shares, “They know when to negotiate and when to assert defenses (“know when to hold ’em, know when to fold ’em”), always aligning their approach with the client’s objectives and risk tolerance.”
In contrast, disputes can take a disastrous turn when a lawyer is more reactive than proactive, isn’t prepared enough, adopts an unnecessarily adversarial posture, or even worsens the situation. This happens when the professional is hyping up the fees to the expense of the client’s best interest in settling. Mistrust surfaces when there is a failure to understand agency priorities or to communicate transparently.
Shifting Enforcement Landscape
When considering whether the rise in Employee Retention Credit and conservation easement disputes points to cyclical compliance waves or a broader shift in IRS oversight, Michelle sees both at play. In her experience, the IRS has long followed a pattern focusing on areas where it senses potential abuse, then moving on as those issues evolve. But this time, the intensity of the enforcement felt different. To Michelle, it reflected a wider, more intentional shift in how the IRS was approaching oversight, even if that momentum has softened more recently.
She remembers how, during that period, the IRS leaned into new tools like advanced data analytics, backed by increased funding, to spot aggressive tax positions more quickly. It wasn’t just about targeting a few problem areas; it felt like part of a bigger effort to strengthen compliance across the board. Then, in early 2025, things changed. Funding cuts and a smaller workforce naturally slowed that pace, and enforcement priorities became less visible.
This quieter phase doesn’t mean the focus has disappeared; it’s more of a pause than a full stop. She believes the IRS will eventually rebuild and turn its attention back to high-risk and emerging areas. For now, though, she understands why things feel less active, given the agency’s current limitations, even if the underlying concerns are still very much there.
Progressive Leadership
Michelle has been working in a leadership position for a long time now and has gained some insights on the same. The sphere has changed dramatically in context to generational shifts, technology, and changing client expectations. In her experience of leading the San Francisco and Silicon Valley offices, she has witnessed how today’s diverse workforce values flexibility, transparency, and inclusion.
She advises that leaders need to foster collaborative environments and prioritize mentorship to support talent across generations. She also stresses that technology has disrupted the way organizations provide services to clients. Also, embracing digital tools and data analytics is now essential for efficiency and responsiveness. It results in clients expecting customized advice and real-time communication.
She adds, “I feel that success hinges on embracing change and empowering teams to deliver exceptional, forward-thinking service.”
Truth Does It
Michelle highlights the complexity in matters alleging fraud, unreported income, or criminal exposure. Says that they’re sensitive and a daunting task to tackle. Both clients and lawyers like her must look at these cases with transparency, integrity, and meticulous substantiation. Doing so brings a balance with the necessity to maintain credibility with the taxing authorities and the client. Clients involved in criminal disputes have their livelihood at risk. Advocacy in a criminal or fraud case oftentimes requires the assertion of certain constitutional and legal protections for the client, which may inflame the taxing agency investigating the client, which can be particularly stressful and difficult.
Her philosophy is to pursue the strongest defense while preserving integrity, ensuring clients are positioned for both legal success and continued credibility in the face of a serious tax dispute or allegation.
She says, “Throughout my career, I have always strived to have reputational credibility with state and federal taxing agencies. While my obligation lies with the clients’ outcomes in their case, experienced and ethical tax controversy lawyers can zealously advocate and be truthful in a client’s defense while at the same time maintaining professional integrity.”
She underlines the fact that lawyers in all practices adhere to this very important tenet in the legal profession.
More Than Just a Specialist
When Michelle thinks about what makes a firm stand out today, she doesn’t see it as a fixed marketing strategy. She knows that in a world where legal problems are becoming more tangled, clients aren’t looking for a box to fit into; they’re looking for someone who can connect the dots. While being a specialist still matters, Michelle believes the real value lies in how we work together. To her, true differentiation is about breaking down the walls between practices and locations so that a client’s experience feels seamless, intuitive, and genuinely helpful.
She also knows that a firm’s brand is really just how they show up every single day. Being quick to respond, staying adaptable, and embracing new technology isn’t just a bonus anymore; it’s the baseline. She pushes for a culture where people never stop learning, but she never loses sight of the old-school fundamentals. At the end of the day, a solid reputation is built on the quiet, consistent work of earning trust and simply being there when it counts.
She adds, “Differentiation is about building enduring relationships based on trust, insight, and a relentless focus on helping our clients succeed, no matter how specialized or complex their needs may be. That’s the value proposition we strive to deliver every day.”
Standing out isn’t about being the loudest in the room. It’s about building the kind of relationship where you understand what a client needs before they even have to ask.
Clearing the Air Around Myths
Michelle hints at the complexity and nuance inherent in the process, which is often misinterpreted in the tax controversy sector. People are blinded by assumptions about numbers or technical interpretations, when in reality it’s about strategy and judgment. It also involves long-term experience, negotiation tactics, and a deep understanding of the regulatory landscape. Leaders, due to a lack of regulatory knowledge, rely on accountants who have filed the return at issue while not giving enough heed to proactive engagement and advanced documentation. Accounting teams do not always account for the ever-present risk of litigation during an audit. In navigating the process with the best of intentions, they may inadvertently make representations that materially steer the outcome away from resolution and toward dispute.
A second mixed-up view she points out was viewing tax controversy as a discrete, isolated event rather than a continuum that can impact broader business objectives. It includes transactions, restructuring, or even long-term growth. Being decisive during such unstable situations can lead to effects on operations, partnerships, company sales, growth, and future compliance. Leaders get carried away at times as they want to get out of the situation, which leads them to not adopt a holistic approach and only focus on the immediate dispute. They should also take into consideration aspects like the strategic implications, missing opportunities to leverage settlement options, preserve advantageous positions, or mitigate risk going forward.
Michelle shares, “From my experience, the most effective approach is holistic and forward-looking: incorporating tax controversy into broader business strategy, engaging expert advisors early, anticipating litigation always, and fostering a culture of compliance.”
She advises that coming to terms with misunderstandings will improve the efficiency in individual disputes and toughen the organization’s overall risk management and decision-making.
Tax Evolved
She sees a decade where the cat-and-mouse game of tax enforcement goes high-tech. With AI now at the helm, tax authorities aren’t just hunting for errors; they’re using lightning-fast analytics to flag patterns and risks before a human auditor even opens a file. This shift toward data-led enforcement means investigations will move faster and hit harder, effectively ending the era of slow, predictable audits and forcing taxpayers to be as digitally fluent as the agencies tracking them.
At the same time, the old walls of financial privacy are crumbling under global transparency rules like the OECD’s reporting standards. Michelle notes that for ultra-high-net-worth individuals and complex entities, there is simply nowhere left to hide. We are entering a glasshouse era where a single red flag in one country can trigger a coordinated, multi-jurisdictional crackdown. As governments get hungrier for revenue, the scrutiny on the world’s wealthiest taxpayers will only intensify, turning local disputes into global headaches almost overnight.
She asserts, “Ultimately, the practice will require agility, collaboration, and a deep understanding of both emerging technologies and global and state policy trends to effectively protect taxpayer interests in a rapidly changing landscape.”
To survive this, Michelle believes practitioners have to stop being purely reactive and start thinking like technologists. The future isn’t just about knowing the law; it’s about having the financial insight and digital agility to build ironclad compliance frameworks long before an inquiry arrives.
