Scott A.& Knott
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Mr. Knott practices exclusively in the area of tax whistleblower claims. In July of 2007, Mr. Knott co-established the tax group at The Ferraro Law Firm and thereafter filed the first of many tax whistleblower claims that exceed a billion dollars. He represents hundreds of whistleblowers before the Internal Revenue Service and in the U.S. Tax Court. To date he has successfully obtained tens of millions of dollars of awards from the IRS for his clients. He has previously 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, often involving tax deficiencies and refunds in the hundreds of millions of dollars. Domestic issue tax controversies that Mr. Knott has experience with relate to tax accounting and timing issues, like-kind exchanges of property, corporate reorganizations, payroll taxes, estate and gift taxes, life and property & casualty insurance, the Research & Experimentation tax credit, Investment tax credit, custom tax shelters, and issues relating to transactions with tax-indifferent parties. Mr. Knott has extensive experience with international tax issues including transfer pricing, the application of treaties to income of non-resident aliens and foreign corporations, permanent establishments, hybrid entities, withholding issues, and the Foreign Sales Corporation and Extraterritorial Income Exclusion regimes.
Mr. Knott's practice before the Internal Revenue Service includes making submissions to the IRS Whistleblower Office, handling communications with the IRS through all phases of a whistleblower claim, and ultimately the filing of appeals of IRS award determinations in the U.S. Tax Court. Mr. Knott previously handled tax disputes from the audit level through the Appeals level on behalf of some of the world’s largest companies, including representing taxpayers in Competent Authority and alternative dispute resolution procedures such as the Pre-filing Agreement and Advanced Pricing Agreement programs. Mr. Knott also has experience with matters that involve tax evasion, fraud and other tax crimes, and has dealt with the IRS Criminal Investigation division and Department of Justice on these matters.
Mr. Knott was previously a management committee co-chair 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, and was also a member of the Baker & McKenzie Washington, D.C. office Business Development and Recruiting committees.
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).
Publications and Articles
- Frequent speaker at tax conferences and regularly quoted on tax whistleblower issues in tax publications such as: Tax Analysts, Tax Notes Today; BNA, Daily Tax Report; CCH, Federal Tax Weekly; as well as mainstream media such as the Wall Street Journal and Bloomberg News.
- Articles and Comments Editor, University of Miami Business Law Review.
- Contributions to the Baker & McKenzie Federal Income Tax Controversies Book, 2005 and 2001 Editions, as well as to Baker & McKenzie’s North American Tax Practice Group Monthly newsletter.
District of Columbia
U.S. Tax Court
U.S. Court of Federal Claims
Georgetown University Law Center, Washington, District of Columbia, 2003
University of Miami School of Law, Coral Gables, Florida, 1999
Honors: Cum Laude
University of Rhode Island, Kingston, Rhode Island, 1994
Professional Associations and Memberships:
Federal Bar Association, Chair - Tax Section, Miami Chapter
American Bar Association
Member - Tax Section
District of Columbia Bar
Member - Tax Section
Florida Bar Association
Member - Tax Section