Search PillsburyLaw.com
  • All
  • Lawyers
  • Capabilities
  • Insights

Phil Wolf

Associate
Silicon Valley

Associate, Silicon Valley

T: +1.650.233.4027
T: +1.650.233.4027

Areas of Focus

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,” August 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, July 15, 2024.
    • “Spanning Two Sovereigns: How Tax Provides the Bridge,” Tax Notes International, June 3, 2024.
    • “Tax Girl: A Powerful and Proud Entrepreneur in Tax,” Tax Notes Federal, April 8, 2024.
    • “When Criminal Cases Have a Tax Angle: Interview with Jon Feldhammer and Brendan Quigley,” Tax Notes Federal, September 4, 2023.
    • “What We Can Learn from New California FTB Notice 2024-01,” Tax Notes State, March 18, 2024.
    • “Women in Tax: The Group Supporting Female Tax Practitioners,” Tax Notes State, Federal and International, January 12, 2024.
    • “Interview with Lachlan Wolfers,” Tax Notes International, November 10, 2023.
    • “Interview with Michael J. Desmond,” Tax Notes Federal, October 26, 2023.
    • “The San Francisco Small Business Expo: A Tax Perspective,” Tax Notes Federal, September 25, 2023.
    • “How to Be Sharp in Tax, not a Texas Sharpshooter,” Tax Notes Federal and International, May 29, 2023 (Republished June 16, 2023).
    • “Navigating Colombia's Challenging Tax System,” Tax Notes International, February 20, 2023 (Republished March 10, 2023).
    • “What Orwell Can Teach Us About Good Tax Writing, Part I: How to Use the Metaphor,” Tax Notes State, Federal and International, February 6, 2023 (Republished February 23, 2023).
    • “Exploring Executive Compensation: Interview with Arthur Kohn,” Tax Notes Federal and Tax Notes Today Federal: Viewpoint, October 17, 2022 (Republished November 3, 2022).
    • “Using Facts (Even Bad Ones) Persuasively in Tax Writing,” Tax Notes International, August 15, 2022 (Republished September 1, 2022).
    • “Building an Award-Winning Transfer Pricing Firm from Scratch,” Tax Notes International and Transfer Pricing Expert, February 21, 2022 (Republished March 11, 2022).
    • “Taxation in Paradise? A Hawaiian Farm’s Choices,” Tax Notes State and Federal, February 7, 2022 (Republished February 24, 2022).
    • “How to Best Strategize in Persuasive Tax Writing,” Tax Notes State, Federal and International, January 24, 2022 (Republished February 10, 2022).
    • “How to Love Writing About Tax Without Falling in Love with Your Own Writing,” Tax Notes State, Federal and International, October 25, 2021 (Republished November 11, 2021).
    • “Manoj Viswanathan: The Professor Who Inspired Me to Love Tax,” Tax Notes Federal, September 6, 2021 (Republished September 23, 2021).
    • “Starting Strong in Tax Writing: The Opening Paragraph,” Tax Notes State, Federal and International, August 23, 2021 (Republished September 10, 2021).
    • “Tax To the Rescue? Tax Challenges and Benefits for a Medium Sized Bakery,” Tax Notes State and Federal, August 9, 2021.
    • “Becoming a Partner in Tax, Life and Loss,” Tax Notes State, Federal and International, July 12, 2021.
    • “California FTB Updates Settlement Procedures,” Tax Notes State, February 9, 2021.
    • “Tax Laws Drive Mission for Children’s Hospice Organization,” Tax Notes State, Federal, The Exempt Organization Tax Review, January 1, 2021.
    • “Reflections on a Year of Challenges and Growth,” Tax Notes State, Federal and International, December 30, 2020.
    • “Learning Tax Means Learning People,” Tax Notes State, Federal and International, November 16, 2020 (Republished December 3, 2020).
    • “From Book Reports to Tax Bedrock,” Tax Notes State, Federal and International, October 26, 2020 (Republished November 12, 2020).
    • “Transitioning From the Top Down to the Bottom Up in Tax,” Tax Notes State, Federal and International, October 5, 2020 (Republished October 22, 2020).
    • “Adapting to the Virtual Tax Practice,” Tax Notes State, Federal and International, August 31, 2020 (Republished September 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, October 1, 2020.
    • “Seeking the Color of My Parachute in Tax,” Tax Notes State, Federal and International, Jul. 20, 2020 (Republished August 5, 2020).
    • “Reaching Out, Not Sticking My Neck Out,” Tax Notes State, Federal and International, June 22, 2020 (Republished July 8, 2020).
    • “Reevaluating California’s Equal Protection Clause Amid COVID-19,” Tax Notes State, June 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, April 27, 2020.
    • “How a String of Model Conventions Led to Unnecessary Confusion in U.S. Tax Treaties,” Tax Notes International, February 24, 2020. 

Education

  • J.D., University of California, Hastings College of the Law, 2019
    Recipient of University of California Provost Scholarship and Pro Bono Award

    LL.M., Taxation, New York University School of Law, 2022
    graduated in the top 10% of his class

    B.A., Geography, University of California, Berkeley, 2016
    Dean’s Honors (Awarded Top 4% of Berkeley Students)

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

Languages

  • Spanish

    French

    Italian

    Portuguese

    Hebrew

    Russian

    Catalan