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Scott’s practice focuses on tax controversies.
He represents investment funds, multinational corporations, trusts, family offices, and high net worth individuals in disputes with the IRS and state and local taxing authorities at the examination and administrative appeals levels. He has handled a wide range of matters, including partnership adjustments, the taxation of derivatives and captive insurance companies, accounting method changes, transfer pricing, statutes of limitations, the application of civil penalties, and voluntary disclosures of delinquent international information returns.
Scott also advises on the tax aspects of domestic and cross-border structuring and planning matters, such as trust restructuring, business formation and exit planning, debt and non-debt financial instruments, investments in controlled foreign corporations and passive foreign investment companies, family investment companies, residency planning, charitable giving, application of tax treaties, and compliance with FATCA and Chapter 3 withholding tax provisions.
His state tax planning experience includes counseling individuals and businesses on residency, sourcing, apportionment, telecommuting, and tax credit issues.