San Francisco Bay Area Tax Attorneys

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.

Tax Litigation

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 clients.

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 taxing authorities.

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 California.

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.

Expert Witness

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 witnesses.

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.

Note: Nothing in this publication is intended or written to be used, and cannot be used by any person for the purpose of avoiding tax penalties regarding any transactions or matters addressed herein. You should always seek advice from independent tax advisors regarding the same. [See IRS Circular 230.]

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Tierney, Watson & Healy provides California probate administration, probate litigation, elder law and estate planning to clients throughout California and nationwide. Our California practice includes the entire San Francisco Bay Area, the cities of San Francisco, Alameda, Oakland, Santa Rosa, Sebastopol and Berkeley. With offices in San Francisco and Sonoma counties, we regularly represent and visit clients in San Francisco County, Alameda County, Contra Costa County, San Mateo County, Marin County and Sonoma County.

Martin J. Tierney  |  Dewey Watson  |  Brian S. Healy  |  Evelyn A. Low
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