Cases
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
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
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
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
use taxes.
Navigated numerous clients through California's complex voluntary disclosure program both at the FTB
CDTFA.
Assisted M&A clients on California tax issues both on buy-side
sell-side transactions.
Represented numerous clients in front of the FTB's protest
settlement units, the CDTFA's appeals board,
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,
unique receipts for sales factor purposes.
The above representations were h
led 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
Managing Director, Andersen Tax, 2006-2007
2012-2018