Joseph M. Bray, J.D.

Senior Associate Tax Attorney

San Francisco, CA
Phone: (415) 394-7200 Fax: (415) 398-6501

Email: Joseph M. Bray

Overview   Experience   Professional Successes   Activities/Honors

Joe is a senior member of the Moskowitz litigation team, entrusted with resolving difficult state and federal tax issues for business owners and individuals. With 15 years of experience handling tax matters and prior roles in government service, Joe has extensive understanding of the taxing authorities and a strong track record of securing good outcomes for clients in challenging circumstances.

He helps clients navigate IRS and state audits and resolves matters related to income, partnership, corporate, sales, and payroll tax, as well as foreign account tax compliance. Joe has particular experience litigating matters involving California tax authorities, including the Franchise Tax Board, State Board of Equalization, and Employment Development Department, and regularly handles California tax residency cases.

In addition to his work on state tax matters, Joe defends taxpayers facing IRS civil penalties, criminal investigations, and claims related to structuring, tax evasion and failure to file, appearing on behalf of clients in U.S. Tax Court and federal district and appeal courts.

He also advises on residential and commercial real estate transactions, and represents clients in general civil litigation matters. Prior to joining the Moskowitz team, Joe represented businesses and individual investors in real estate transactions in California and beyond. He gained early insight into government processes as a former intern for the White House Office of Legislative Affairs, the California State Treasurer’s Office and the California State Assembly.

Joe continually monitors changes to prevailing tax law and contributes to the Moskowitz LLP Tax Law blog.

Joe has helped clients with a wide range of tax and tax-related matters, including the following:

  • IRS and state audits, including eggshell and reverse eggshell audits
  • Resolution of income, partnership, corporate, sales and payroll tax matters
  • California Franchise Tax Board disputes
  • California State Board of Equalization disputes
  • California Employment Development Department disputes
  • California tax residency and multi-state matters
  • Offshore bank account and asset tax compliance
  • Foreign asset reporting and compliance
  • Internal Revenue Service civil and criminal investigations
  • Internal Revenue Service administrative hearings and appeals
  • Defense against criminal charges related to structuring, tax evasion, and failure to file
  • U.S. Tax Court litigation
  • Federal district and appeals court litigation
  • Commercial and residential real estate transactions, including acquisitions, dispositions, leasing, financing, and taxation aspects
  • Civil litigation
  • Marital agreements

  • IRS audit; Result: IRS concedes, no changes to tax computation
  • Criminal Tax Investigation; DOJ recommends NO prosecution
  • Criminal Tax Investigation; Result: Tax Perjury Plea, Sentence: 24 months
  • Advise U.S. and international clients on the tax implications of their real estate investments
  • Advise on the tax aspects of real estate transactions, from property acquisitions and sales, to 1031 or “like-kind” exchanges, to structuring condo-hotels, club membership programs and other ancillary service programs
  • Advise on a wide range of state tax matters, including corporate and personal income taxes, sales and use taxes, and real property taxes
  • Advise clients on the state and local tax issues involved in their corporate transactions
  • Advise on a broad range of tax issues, including handling sensitive ("eggshell") audits, counseling on tax compliance and reporting, compromising tax debts, defending reporting positions, resolving employment tax issues and obtaining contested tax refunds
  • Advise on the tax collection process and dealing with sensitive tax issues that arise in business and personal settings and in tax fraud investigations
  • Represent clients during audits, handling administrative appeals in the Appeals Office of the Internal Revenue Service and the appellate level of state and local tax agencies
(Note: These case examples do not guarantee a similar result; See Disclaimer).

McGeorge School of Law - Dean's List and Oral Advocacy Competition Award

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Education

University of the Pacific - McGeorge School of Law, J.D.
  - Dean’s List, Oral Advocacy Competition Award at McGeorge School of Law

University of California – Davis; B.A., with honors
  - Selected to Golden Key and Political Science Honor Societies

Bar Admissions

California

Court Admissions

U.S. Tax Court
U.S. District Court – Northern, Southern, Eastern and Central Districts of California
U.S. Court of Appeals – Ninth Circuit
California Supreme Court

Affiliations

  • Member, American Bar Association – Taxation Section
  • Internship experience at White House Office of Legislative Affairs, California State Assembly, California State Treasurer’s Office

Practice Areas

  • Tax Transactions and Litigation
  • Criminal Tax Investigations and Litigation
  • Civil Litigation
  • International Tax
  • Real Estate Tax
  • Real Estate Law
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