Matthew Wong
State and Local Tax (SALT) Attorney
I am a California licensed attorney residing in San Francisco, currently at Silverstein & Pomerantz, a boutique State and Local Tax (SALT) controversy law firm. S&P represents businesses and individuals in matters involving sales, use, franchise, income, and transaction taxation – often involving either audits or disputes, and before both administrative and judicial bodies – relating to every type of government jurisdiction; state, county, city, and others – almost exclusively in California. I have continued my professional development by attending the 31st annual Summer Tax Institute (formerly the Center for SALT) at the UC Davis School of Law, in June 2023, via the Comprehensive Multistate Corporate Income Tax program.
During law school at UC Davis, I focused my studies on business law (especially securities) and federal tax law. Looking back, I was a Research Assistant for Prof. Menesh Patel, with a focus on SEC Rule 10b-5 issues. That built on my experience as a remote intern for the U.S. Securities and Exchange Commission in Washington, D.C. as a part of the Division of Enforcement, assisting an investigative team. The summer prior, I worked as a legal intern for Glass House, a vertically integrated cannabis company, doing regulatory and compliance research for the eldest nascent Californian industry. My first summer, I was a research assistant for Prof. Shayak Sarkar, citation checking, proofing, and researching for his law review articles, particularly regarding consumer protection law.
Prior to law school, I worked as a legal assistant and paralegal for a boutique litigation firm in San Francisco, then called Cannata, O’Toole, Fickes & Olson, gaining broad experience with civil litigation; discovery, law and motion, and trial practice. Before that, I was inspired to pursue a legal career by observing unforgettable complex civil litigation trials during my judicial externship at the San Francisco Superior Court. That program was made possible by the Political Science department at San Francisco State University where I received my undergraduate degree in 2018; a B.A. in Philosophy & Law, with a minor in Political Science.
Education:
J.D. Class of 2022
University of California, Davis
King Hall School of Law
Business Law and Tax Law Certificates
Capstone: A Primer on IRC § 1202 Qualified Small Business Stock
3L: (Fall) Corporate Income Taxation, Will & Trust Drafting, U.S. Securities and Exchange Commission Student Honors Legal Program internship, Law and Lawyering in the Nation's Capital seminar. (Spring) Tax & Distributive Justice, Legal Ethics & Corporate Practice, Business Fundamentals [Accounting & Finance for Lawyers].
2L: (Fall) Appellate Advocacy I, Business Associations, Federal Income Taxation, Trusts, Wills, and Estates, Intellectual Property, White Collar Crime. (Spring) Appellate Advocacy II, Evidence, Marital Property, Securities Regulation, Taxation of Partnerships [IRC Subchapter K], Jurisprudence.
[Business / Tax / Dual Qual.]
Organizations: Moot Court Honors Board (‘22 Spring Competition Problem Writer), Asian Pacific American Law Student Association (APALSA) (18th Annual Banquet Chair), Cannabis Law Society (CLAWS) (‘22/’23 President), Lambda LSA (Member).
Sample Work
My capstone paper was meant to demonstrate general proficiency in tax and business law, specifically: in corporate income tax provisions; specialized securities financing instruments; and some accounting and valuation concepts. For those less interested in the intricacies of the Internal Revenue Code, I suggest reading the paper backwards. Begin with Part II (p. 14) to understand the loophole that is Sec. 1202, in broad strokes, and to learn who is taking advantage of such a fortuitous tax break. That section, and the paper, ends with some politics. Then, if desired, Part I contains the dry statutory mechanistic and accounting details.
I wrote all portions of the 8th Amendment issue, and co-wrote factual portions of the ‘22 Neumiller Problem for the UC Davis Moot Court Competition (intrascholastic). It is formatted as two mock opinions (a lower federal District Court and appellate Circuit Court) taking contrary positions on a civil rights issue; prison conditions of confinement. Specifically, I wanted to raise awareness regarding the use of solitary confinement on prisoners with mental illnesses, by examining 8th Amendment “cruel and unusual” punishment jurisprudence.
Previously:
U.S. Securities and Exchange Commission - Division of Enforcement
Student Honors Program, Legal Intern (Fall 2021)
The SEC is an independent federal agency responsible for the administration of the various federal securities laws, with a broad regulatory scope ranging from matters of securities registration, issuance, and resales; to corporate disclosure and governance; broker-dealer and investment adviser regulation; and fraudulent practices and market manipulation.
I worked remotely within the Enforcement Division, the largest of the six SEC branches, assisting a general litigation group with investigations into all kinds of securities law violations, e.g. fraud and misrepresentation in connection with the purchase or sale of any security (Rule 10b-5); unregistered broker-dealer conduct, and issuer disclosure matters. Each investigation was unique and developed facts by analyzing information provided by witnesses, documents, and data. I assisted the investigative team primarily by reviewing case documents in preparation for witness testimony, and also by performing document review and tagging of evidentiary productions. I also conducted research regarding securities regulations, including convertible bond arbitrage and unregistered broker/dealer liability.
Unaffiliated with the SEC, and reflecting my own research and conclusions based entirely and exclusively on publicly available information, I created a presentation, Convertible Securities, Toxic Lenders, and Unregistered Dealer Liability, and wrote an associated paper. That high-level presentation with accompanying script, and short paper covering substantively the equivalent topic, is available below.
Glass House Brands
Legal Intern (Summer 2021)
Glass House is a vertically integrated producer and seller of adult-use and medicinal cannabis and related products in California. Glass House Group has been cultivating cannabis since 2015, and is one of the largest operators in California. As of this writing in Q3 2022, Glass House possesses an aggregate of over 500,000 sq. ft. of cultivation facilities, two manufacturing facilities (one volatile facility), and is expected to reach 21 operational dispensaries in California by the end of 2022. Glass House was acquired via SPAC by Mercer Park for $567M in April 2021.
I conducted legal research of recent (and often nascent or pre-operative) California county and municipal cannabis regulations, especially with respect to the operation, licensure, and ownership of retail cannabis dispensaries. Broadly, I performed research and diligence regarding licensing, permit applications, feasibility, and transactional structuring, as well as reviewing commercial agreements and initial drafting of internal policies and other documents. My many thanks to fellow UC Davis alumni, Jamin Horn — then G.C. — for those opportunities.
UC Davis School of Law - Professor Shayak Sarkar
Research Assistant (Summer 2020)
I assisted Professor Sarkar (my torts teacher) with proofreading for law review articles, particularly for one examining consumer protection regulation in the areas of graduate education, homeownership, and retirement savings. I also conducted research regarding the qualified hardship withdrawal requirements of 401(k) plans, and spousal income assessments for Medicare eligibility (i.e., impoverishment provisions).
Cannata O’Toole Fickes & Olson
Paralegal and Legal Assistant (July 2018 - August 2019)
At COFO, I performed paralegal and legal support duties for a nine-lawyer firm with pending civil litigation matters in state and federal courts throughout California. My responsibilities included: working with attorneys to prepare, edit and proofread legal correspondence, written discovery, and court filings; assisting with preparation for court hearings, arbitration, depositions, and trials; attending and assisting at hearings and trials; summarizing, organizing, and managing large document productions, case and client materials, deposition transcripts, and expert reports; coordinating meetings and conference calls; calendaring appointments and litigation deadlines; interfacing with public agencies and court clerks to obtain and deliver documents; and management of filing and record keeping systems, both digital and physical.
At a small firm — you do it all: I got a very wide and enjoyable variety of experiences during my time at COFO. A brief subject-matter sampling would include: Public Records Act / Freedom of Information Act Requests (especially Petitions for Writ of Mandate); Clean Water Act litigation; as well as breach of contract and other general business litigation; and preparation for at least four separate trials, to varying levels of completion. My many thanks to Therese Y. Cannata, Karl Olson, and Mark P. Fickes, for trusting me with great responsibilities in each of their respective practices.
San Francisco State University
B.A. Philosophy & Law - Minor in Political Science (2018)
I owe a profound debt of gratitude to everyone who taught me anything, but in particular, to a few of my undergraduate professors.
Of the philosophy department, my thanks to: Mme. Isabelle Peschard for an introduction to first‐order logic; to Prof. Kevin Toh for a rigorous and fascinating look at the philosophy of law and jurisprudence; to Chris Daley (then GTA, now Esq.) for a primer on contemporary moral and political issues; to Dr. James Blackmon, for a prescient illustration of the connections between computation and cognition (e.g., Babbage’s engine, Turing machines, Searle’s Chinese early language transformer, and artificial general intelligence), as well as an examination of the thinking about consciousness itself; to M. Yann Benétreau‐ Dupin for delightfully equating change ringing, harmonics, temperament, Brunelleschi and Aleberti – to mathematical permutations and groups, intervals as frequencies and operations on powers and rational and irrational numbers, and projective geometry, respectively; and especially to Prof. Abrol Fairweather, for shedding light on some of the endlessly fascinating and potentially undecidable problems of epistemology and metaphysics; if I ever have a (virtuous) justified true belief, I will know I know it, thanks to him.
Equally, of the political science department, my many thanks to inimitable Prof. Ali Kashani (sui generis) for his pedagogical praxis with regards to American politics, critical social thought, and in particular, Foucault; to Bill Sokol, Esq. for his excellent seminars on collective bargaining and labor rights law in California; and notably to Dr. Martin Carcieri for his honest and acerbic wit in teaching judicial process and jurisprudence, and guiding judicial externs; and especially, to Dr. Nicholas D. Conway, for his clever and passionate coaching on the use of tactical rhetoric (both oral and written) in moot court, as well as for sharing his deeply sagacious, analytical, and quantified approach to social, legal, and political questions.
Superior Court of California, San Francisco
Judicial Externship (Fall 2017)
As a part the Political Science Department at SFSU, I was a judicial extern at the Superior Court of California, County of San Francisco, Civil Division, Dept. 606 (Judge Andrew Y.S. Cheng). I sat as a court observer at various stages of complex civil legal and trial proceedings including: pre-trial and status conferences; voir dire; opening and closing arguments; lay and expert witness testimony and cross-examination; sidebar and in camera meetings; jury deliberation and verdict; post-trial and law and motion proceedings; and a bit of followup in related parallel and appellate cases. I developed a strong interest in both the procedure and substance of civil litigation; the subject matter of cases included: employment contract disputes (Brogan v. DGH, CGC-16-549951); landlord / tenant issues (Duncan v. Kihagi, CGC-15-545655, CCSF v. Kihagi, CGC-15-546152; Court says landlord must pay SF $2.4 million for bad evictions, SF Chronicle May 2, 2017; Notorious SF landlord slapped with $3.5 million judgment for wrongful eviction, SF Chronicle Oct 27, 2017); and asbestos/mesothelioma (Lucas v. Certainteed Corporation, et al., CGC-16-276549), among others. I also visited other local courtrooms and courts to witness proceedings at the SF Hall of Justice, the United States District Court, and the 9th Circuit Court of Appeals. (These are all within a ~1mi radius of each other.)
Recreational Equipment, Inc.
Retail Sales and Operations Specialist (November 2010 - May 2015)
I started in the warehouse, and grew to provide customer service and sales support for REI, a retail co-op with a strong member culture. I helped manage departmental warehouse space and inventories, and optimized layouts to increase workflow efficiency while maintaining safety standards. I developed skills as a fast-paced multitasking coordinator, with an eye for perfection, and I provided training and culture onboarding support for new hires and departmental transfers. I developed extensive gear expertise in the field of outdoor apparel, footwear, and some action sports. I worked at the REI Roseville store from 2010 - 2014, and the San Francisco store from 2014 - 2015.
Rotary (International) Youth Exchange
Student Ambassador (2009/2010)
I was a Student Ambassador (exchange student) to Lille, France, in the Rotary Youth Exchange program, for a year long study-abroad, in lieu of my senior year of high school. I developed a high degree of self-reliance and independence, as well as flexibility, adaptability, and general problem solving skill. It’s amazing how much one can pantomime in lieu of fluency, and of necessity, I learned how some silvertongue can solve sticky situations. I gained experience in public speaking, presentation, and diplomacy, and I achieved deep conversational proficiency in speaking French (and to a lesser extent, writing). I am eternally grateful to the Rotarians of Districts 1520, Lille (grâce à M. Marc-Henry Bataille, parmi tant d'autres); and 5180, Auburn (thanks to Lee Oelke, among many others) and above and beyond that, my three angelically graceful familles d'accueil.