Scott A. Knott - Miami, FL

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: