Pietro Canestrelli

Pietro E. Canestrelli is a California State Bar–Certified Specialist in Taxation Law with more than 27 years of experience helping business owners and individuals protect what they’ve built. While he is widely known for his success in tax controversy and Tax Court litigation—representing hundreds of taxpayers before the IRS, U.S. Tax Court, U.S. District Court, and California taxing authorities, Pietro’s core philosophy is simple: the best tax controversy is the one that never happens. Through proactive, year-round tax planning, Pietro helps business owners stay educated, compliant, and strategically positioned long before tax problems arise. By aligning entity structure, income timing, transactions, and long-term business goals with the tax code, he works to eliminate surprises at year-end and reduce the risk of audits, penalties, and litigation. For clients who do face disputes, his deep litigation and agency experience provides unmatched protection but his mission is to keep business owners out of tax court altogether by replacing reactive firefighting with deliberate, forward-looking tax strategy. Trust Fund Recovery Penalty (TFRP): What California Business Owners Must Know If you own or manage a business in California and your company falls behind on payroll taxes, you face one of the most aggressive penalties in the entire tax code: the Trust Fund Recovery... ERC Under Fire: What to Do If the IRS Is Auditing Your Employee Retention Credit Claim The Employee Retention Credit (ERC) was one of the most generous COVID-era tax benefits available to businesses — potentially worth up to $26,000 per employee for qualifying... Form 1099-DA Is Here: What California Crypto Investors Need to Know About the New Reporting Rules The era of reporting cryptocurrency on the honor system is over. Starting with tax year 2025, custodial crypto brokers — Coinbase, Kraken, Gemini, and others — are...