Attorney Scott Knott, The Ferraro Law Firm, Coral Gables, Florida

Scott A. Knott
Washington, District of Columbia


phone	(800) 275-3332 (Toll Free)
fax	(202) 775-1633
email	Email Me

contact us for IRS tax whistleblower or Personal Injury issues .

Mr. Knott practices primarily in the area of tax whistleblower claims and federal tax controversies. As a member of Baker & McKenzie's Global Tax Practice Group from 1998 through 2007, he has represented many multi-national corporations, high-net worth individuals, foreign governments, and underprivileged taxpayers before the Internal Revenue Service and in litigation in the U.S. Tax Court and federal courts.

Mr. Knott has handled both international and domestic tax issues, and these issues have often involved tax deficiencies and refunds in the hundreds of millions of dollars. Domestic issue tax controversies that Mr. Knott has experience with relate to life and property & casualty insurance, the Research & Experimentation tax credit, Investment tax credit, tax accounting and timing issues, like-kind exchanges of property, and issues relating to transactions with tax-indifferent parties. Mr. Knott also has extensive experience with international tax issues including the application of treaties to income of non-resident aliens and foreign corporations, the Foreign Sales Corporation and Extraterritorial Income Exclusion regimes, and transfer pricing.

Mr. Knott 's practice before the Internal Revenue Service includes making submissions to the IRS Whistleblower Office and also handling tax disputes from the audit level through the Appeals level, including Competent Authority and alternative dispute resolution procedures such as the Pre-filing Agreement and Advanced Pricing Agreement programs. He also regularly counsels taxpayers on steps to be taken before controversies with the Internal Revenue Service arise and strategic considerations with respect to filing claims for refund. Mr. Knott was previously on the management committee of the Tax Controversy Subpractice Group of Baker & McKenzie's North American Tax Practice Group, which was ranked as one of the top five tax litigation practices in the United States by Chambers & Partners USA, 2007 edition.

In addition to non-docketed matters, his principal docketed cases include:

Abbott Laboratories and U.S. Subsidiaries v. United States, U.S. Court of Fed. Claims No. 06-778 (statute of limitations issue with respect to timeliness of claims for refund relating to Foreign Sales Corporation commission redeterminations).

American International Group, Inc. v. Commissioner, U.S. Tax Court No. 00852-04 (proper treatment of salvage and subrogation costs of a property & casualty insurance company).

Boeing Co. v. United States, 123 S. Ct. 1099 (2003) (Amici Curiae for Brunswick Corp., Hewlett-Packard Co., Intel Corp., Reebok International Ltd., et al.) (allocation of R&D expenses in computing export benefits).

Borden, Inc. v. United States, U.S. Court of Fed. Claims No. 93-779T (qualification of property for energy tax credit).

Clara Weyh-Templin v. Commissioner, U.S. Tax Court No. 018831-02 (innocent spouse relief under the equitable provisions of I.R.C. 6015(f)).

Nenkin Shikin Unyo Kikin, a.k.a., Government Pension Investment Fund v. Commissioner, U.S. Tax Court No. 10356-00 (successfully claimed entitlement of arm of Government of Japan to exemption from tax under I.R.C. 892 with respect to U.S. source investment income, and related commercial activity issues).

Nenkin Shikin Unyo Kikin, a.k.a., Government Pension Investment Fund v. United States, U.S. Court of Fed. Claims No. 06-218 (successfully claimed refund of all taxes withheld with respect to the U.S. source investment income of an arm of Government of Japan under I.R.C. 892).

SunAmerica, Inc. and Subs. v. Commissioner, U.S. Tax Court No. 10438-06 (Internal Revenue Service challenged the computation of the reserves under I.R.C. 807 of a subsidiary of American International Group, Inc. (AIG) with respect to Guaranteed Investment Contracts and asserted certain other insurance tax issues).

Bar Admissions:: District of Columbia; Florida; U.S. Tax Court; U.S. Court of Federal Claims

Education:: Georgetown University Law Center, Washington, District of Columbia, 2003
L.L.M.
Major: Taxation; University of Miami School of Law, Coral Gables, Florida, 1999
J.D.
Honors: Cum Laude; University of Rhode Island, Kingston, Rhode Island, 1994
B.S.B.A.

Professional Associations and Memberships:: American Bar Association; Member - Tax Section; District of Columbia Bar; Member - Tax Section; Florida Bar Association; Member - Tax Section

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