Francisco Bay Area Tax Attorneys
Tax Litigation | Intl. Tax Law |
ERISA | Section 1031 |
Over the past two decades, Tierney, Watson & Healy has grown into one
of the nation's foremost boutique tax law firms. Six of our eight
members hold advanced tax degrees, so we're ready to help you or your
company with almost any domestic or foreign tax issue.
And when the corporate tax solutions involve integrating the personal
concerns of the principals, we offer knowledgeable advice on estate,
pension and individual tax planning strategies. If those tax issues
involve disputes, Tierney, Watson & Healy has the nation's foremost tax
litigator to advance your cause.
Tierney, Watson & Healy is one of the few tax litigation firms in the
nation that specializes in substantial issues of law or fact. We have
built a reputation with both the courts and the IRS that serves our
clients exceptionally well. Led by Ben Sanchez, former Western Regional
Counsel for the IRS — and one of the agency's top litigators — our
controversy practice has consistently come home with victories for our
In 1999, we obtained, in one case alone, more than $15 million in
refunds for a group of clients by overturning a Tax Court ruling in the
9th Circuit Court of Appeals. In the same year, a multinational client
received a "no change" determination on the eve of trial after an
initial assessment well into the seven figures.
Put another way, Tierney, Watson & Healy can go head-to-head with the
IRS and win. We are not afraid to litigate and the IRS knows this well.
In addition, we are regularly called in as a consultant to assist
attorneys or accountants with IRS procedure. Our expertise can often
spot procedural gaffes by taxing authorities that can result in a
withdrawal of the audit or notice of assessment.
Because of this ability to resolve tax issues at the highest levels,
Tierney, Watson & Healy is an excellent resource for accounting and law
firms whose clients have substantial and/or complex legal issues with
Moreover, our highly specialized focus means a professional firm can
feel confident and comfortable retaining our firm to work with its
clients without concern about competition.
International Tax Practice
Subsection F of the Internal Revenue Code - dealing with
international tax law - is a very complicated tax area explored by few
practitioners in the United States.
Straddling the Pacific Rim through offices in Hong Kong and San
Francisco, Tierney, Watson & Healy has advised Asian investors in the
United States from both sides of the ocean, and is well-equipped to
address questions of doing business in the United States or individual
tax issues of foreign nationals.
Oliver Silsby has practiced US law in Asia since 1985. Currently
commuting between Hong Kong and Taiwan, his knowledge of the Far East is
unsurpassed in an American lawyer.
Oliver, along with Martin Tierney in our San Francisco office, gives
the firm a steady and seasoned anchor on both sides of the Pacific.
Mergers, Acquisitions, & Sales
Tierney, Watson & Healy has broad experience with corporate sales,
mergers and acquisitions, from complex transactions such as a reverse
triangular merger to a simple Subpart F sale. At any level of
complexity, we can advise you on the best course.
We are frequently called upon to render opinions in public and
private offerings, and regularly advise other counsel and accountants on
strategies for maximizing the tax benefits of their client's deal.
Among our experts in this field, Martin Tierney has, for many years,
taught the Reorganizations course to hundreds of lawyers and
accountants, and is a recognized expert in the field.
Employee Income Retirement Safety Act (ERISA)
For a small firm, Tierney, Watson & Healy is unique in its ability to
provide expert counsel on employee pension and benefit planning,
particularly regarding the Employee Retirement Income Security Act (ERISA).
ERISA governs the entitlement of workers to health care, disability
payments, life insurance and pensions.
Evelyn Low has practiced in this specialized area for 27 years,
advising small and large corporations of their rights and duties under
the statute. She has also created programs and worked with start-up
companies to integrate their retirement and business plans.
Real Estate & Section 1031
Tierney, Watson & Healy is well versed in the rules relating to the
ownership and sale of real estate assets. Dewey Watson has represented
real estate partnerships, LLCs and individuals for over 30 years.
In addition, he is a licensed real estate broker and is the broker of
record for three national corporations doing mortgage lending in
Mr. Watson is recognized as an expert in Section 1031 of the tax
code, which allows for compounding real estate equity in order to avoid
unnecessary capital gains taxes. He was also the owner of Property
Exchange Professionals, a company which acted as the intermediary in
hundreds of transactions. Learn more
about the tax-free Section 1031 Exchange.
Not all of our practice involves offering counsel and representation
to clients. Because of our unique understanding of tax and corporate
law; international trade and commercial banking, our partners and
associates are regularly called upon to testify at trial as expert
Martin Tierney and Dewey Watson are often called as experts in
litigation involving interpretation of the tax and real estate laws. Mr.
Tierney has testified in a bank merger case with liabilities exceeding
$200 million. Mr. Watson has testified in both civil and criminal real
estate fraud cases involving millions of dollars of liability.
As former professors of tax law (foreign and corporate for Mr.
Tierney, real estate for Mr. Watson), both attorneys are well qualified
to render opinions in tax cases. In addition, both have extensive
experience in general corporate and real estate law, so they are able to
present a broader perspective than just tax aspects alone.
Benjamin C. Sanchez, a former top attorney for the Internal Revenue
Service, is one of the foremost experts on tax procedure in the United
States. After leaving the IRS, he served as Acting Dean of the Master of
Laws program of Golden Gate University. The weight of his opinion is
frequently sought in complex and sophisticated tax proceedings.
Frederick Daily is a noted author and lecturer and is a frequent
guest in the national media.
Mr. Daily is also a popular arbitrator for the American Arbitration
Association and thus has experience both as a jurist and as an advocate.