Phil Wolf focuses on tax and accounting controversies, with a primary emphasis on property taxes, transfer taxes, sales and use taxes, and income and franchise taxes.
Phil represents businesses and property owners in valuation disputes, assessment appeals, and refund claims, providing practical, results-oriented strategies to minimize tax exposure and resolve conflicts efficiently. He also advises on transactional property tax issues throughout California, including change-in-ownership and legal entity transfers, exclusions, and planning for complex real estate transactions. He has advised clients facing internal and government investigations involving allegations of noncompliance, fraud or misconduct, with a particular emphasis on tax and accounting matters. He draws on substantial experience practicing before numerous government agencies and regulators, including county assessors and assessment appeals boards across California, the California Franchise Tax Board, the California Department of Tax and Fee Administration, the IRS, the DOJ Tax Division, the SEC Enforcement Division, the FBI and other government agencies. His practice frequently involves cutting-edge issues concerning power-generating facilities, clean energy, financial products, digital assets, artificial intelligence and quantum computing.
Representative Experience
- Represented a major power company in analyzing and addressing the California property tax implications arising from its acquisition by an out-of-state corporation, including change-in-ownership and legal entity transfer considerations.
- Advised numerous businesses on tax and accounting compliance issues and controversies, particularly those involving complex, disputed, or missing documents or returns (in both civil and criminal contexts).
- Defended an executive of a publicly traded company in a cross-border investigation. As a result of his representation, no charges were filed against the client.
Professional Highlights
An active contributor to the field, Phil has authored more than 40 articles published in Tax Notes State, Tax Notes Federal and Tax Notes International, covering topics ranging from property tax reform to tax policy in emerging technologies.
He is admitted to practice in California, the U.S. Tax Court, the U.S. District Court for the Northern District of California and the U.S. Court of Appeals for the Ninth Circuit.
Phil is fluent in Spanish, Portuguese, Russian, and Catalan, and conversational in Hebrew, Italian, and French.
View More
- Publications
- Tips for Avoiding Pretentiousness in Tax Writing, Tax Notes State, Tax Notes Federal, June 10, 2025.
- Women in Tax: Navigating the Digital Tax Landscape, Tax Notes International, May 19, 2025.
- Is Quantum Computing the End of the Tax Profession? Tax Notes Federal, May 17, 2025.
- How to Effectively Use the Taxpayer Advocate Service. Tax Notes Federal, April 17, 2025.
- How to Sell the Sizzle in Tax Writing. Tax Notes Federal, April 10, 2025.
- Avoiding IRS Criminal Investigations: An Interview with CI’s Former Chief. Tax Notes Federal, Feb. 26, 2025.
- Four Must-Read 2024 Tax Court Decisions. Tax Notes Federal, Oct. 31, 2024.
- How Your Workers’ Location May Affect Your San Francisco Gross Receipts Tax. Tax Notes State, Oct. 3, 2024.
- United by Tax: An Interview with Chile’s Fernanda Yoma Schrader. Tax Notes International, Sep. 9, 2024.
- What Happens if I Am Contacted by the California Franchise Tax Board? Fiscalía Magazine, Aug. 29, 2024. (Publication in Spanish. Original title: ¿Qué sucede si soy contactado por el California Franchise Tax Board?)
- A Window into the Life of an Enrolled Agent and the Black Taxpayer Community. Tax Notes Federal, Jul. 15, 2024.
- Spanning Two Sovereigns: How Tax Provides the Bridge. Tax Notes International, Jun. 3, 2024.
- Tax Girl: A Powerful and Proud Entrepreneur in Tax. Tax Notes Federal, Apr. 8, 2024.
- When Criminal Cases Have a Tax Angle: Interview with Jon Feldhammer and Brendan Quigley. Tax Notes Federal, Sep. 4, 2023.
- What We Can Learn from New California FTB Notice 2024-01. Tax Notes State, Mar. 18, 2024.
- Women in Tax: The Group Supporting Female Tax Practitioners. Tax Notes State, Federal and International, Jan. 12, 2024.
- Interview with Lachlan Wolfers. Tax Notes International, Nov. 10, 2023.
- Interview with Michael J. Desmond. Tax Notes Federal, Oct. 26, 2023.
- The San Francisco Small Business Expo: A Tax Perspective. Tax Notes Federal, Sep. 25, 2023.
- How to Be Sharp in Tax, not a Texas Sharpshooter. Tax Notes Federal and International, May 29, 2023 (Republished Jun. 16, 2023).
- Navigating Colombia's Challenging Tax System. Tax Notes International, Feb. 20, 2023 (Republished Mar. 10, 2023).
- What Orwell Can Teach Us About Good Tax Writing, Part I: How to Use the Metaphor. Tax Notes State, Federal and International, Feb. 6, 2023 (Republished Feb. 23, 2023).
- Exploring Executive Compensation: Interview with Arthur Kohn. Tax Notes Federal and Tax Notes Today Federal: Viewpoint, Oct. 17, 2022 (Republished Nov. 3, 2022).
- Using Facts (Even Bad Ones) Persuasively in Tax Writing. Tax Notes International, Aug. 15, 2022 (Republished Sep. 1, 2022).
- Building an Award-Winning Transfer Pricing Firm from Scratch. Tax Notes International and Transfer Pricing Expert, Feb. 21, 2022 (Republished Mar. 11, 2022).
- Taxation in Paradise? A Hawaiian Farm’s Choices. Tax Notes State and Federal, Feb. 7, 2022 (Republished Feb. 24, 2022).
- How to Best Strategize in Persuasive Tax Writing. Tax Notes State, Federal and International, Jan. 24, 2022 (Republished Feb. 10, 2022).
- How to Love Writing About Tax Without Falling in Love with Your Own Writing. Tax Notes State, Federal and International, Oct. 25, 2021 (Republished Nov. 11, 2021).
- Manoj Viswanathan: The Professor Who Inspired Me to Love Tax. Tax Notes Federal, Sep. 6, 2021 (Republished Sep. 23, 2021).
- Starting Strong in Tax Writing: The Opening Paragraph. Tax Notes State, Federal and International, Aug. 23, 2021 (Republished Sep. 10, 2021).
- Tax To the Rescue? Tax Challenges and Benefits for a Medium Sized Bakery. Tax Notes State and Federal, Aug. 9, 2021.
- Becoming a Partner in Tax, Life and Loss. Tax Notes State, Federal and International, Jul. 12, 2021.
- California FTB Updates Settlement Procedures. Tax Notes State, Feb. 9, 2021.
- Tax Laws Drive Mission for Children’s Hospice Organization. Tax Notes State, Federal, The Exempt Organization Tax Review, Jan. 1, 2021.
- Reflections on a Year of Challenges and Growth. Tax Notes State, Federal and International, Dec. 30, 2020.
- Learning Tax Means Learning People. Tax Notes State, Federal and International, Nov. 16, 2020 (Republished Dec. 3, 2020).
- From Book Reports to Tax Bedrock. Tax Notes State, Federal and International, Oct. 26, 2020 (Republished Nov. 12, 2020).
- Transitioning From the Top Down to the Bottom Up in Tax. Tax Notes State, Federal and International, Oct. 5, 2020 (Republished Oct. 22, 2020).
- Adapting to the Virtual Tax Practice. Tax Notes State, Federal and International, Aug. 31, 2020 (Republished Sep. 17, 2020).
- A Four-Factor Framework for Analyzing the Taxation of Tech Companies with Limited to No Physical Presence. Tax Notes State, International and Special Reports, Oct. 1, 2020.
- Seeking the Color of My Parachute in Tax. Tax Notes State, Federal and International, Jul. 20, 2020 (Republished Aug. 5, 2020).
- Reaching Out, Not Sticking My Neck Out. Tax Notes State, Federal and International, Jun. 22, 2020 (Republished Jul. 8, 2020).
- Reevaluating California’s Equal Protection Clause Amid COVID-19. Tax Notes State, Jun. 18, 2020.
- Family Court Attorney Fees for Innocent Spouses in Tax Court. Tax Notes State and Federal, May 25, 2020.
- Learning Entry-Level Tax Skills Without an Entry-Level Tax Job. Tax Notes State, Federal and International, May 25, 2020.
- How a New Tax Lawyer’s Collision With the COVID-19 Job Market Led to Opportunities. Tax Notes State, Federal and International, Apr. 27, 2020.
- How a String of Model Conventions Led to Unnecessary Confusion in U.S. Tax Treaties. Tax Notes International, Feb. 24, 2020.
Education
-
J.D., University of California, Hastings College of the Law
LL.M., New York University School of Law
B.A., Geography, University of California, Berkeley
Admissions
-
California
Courts
-
U.S. Tax Court
U.S. District Court for the Northern District of California
U.S. Court of Appeals for the Ninth Circuit