Profile

Scott Manning focuses his practice on federal, state and international tax planning. He advises clients on a wide variety of tax matters, including corporate formations, tax-free reorganizations, taxable acquisitions, corporate separations, joint ventures, and both inbound and outbound tax planning.

Additionally, Mr. Manning regularly advises tax-exempt organizations, including public charities, private foundations and trade associations on a wide range of issues related to establishing and preserving tax-exempt status, complying with regulatory requirements, and minimizing income and excise tax exposure. He also represents clients in tax controversies before the IRS and the United States Tax Court.

From 2004 to 2006, Mr. Manning served as attorney-advisor to the Hon. Thomas B. Wells of the United States Tax Court in Washington, D.C. Prior to law school, Mr. Manning served for several years as a legislative aide on Capitol Hill.

Experience Highlights

• Advises clients on the tax aspects of stock and asset sales
• Prepares partnership agreements, LLC operating agreements, and tax sharing agreements
• Provides advice on the U.S. tax implications of cross-border transactions
• Represents clients in domestic and international corporate restructurings
• Represents clients in all types of tax-free reorganizations
• Prepares private letter ruling requests from the IRS national office
• Advises clients on the applicability of state income, sales, use, franchise, and property tax
• Represents clients in all stages of tax controversies, including examinations, administrative appeals, Tax Court proceedings, and collection matters
• Drafts and negotiates tax provisions of equipment lease and finance agreements

Publications

Co-author, ”IRS Expands Ability to Treat Stock Sales as Asset Sales,” Corporate Advisory, September 5, 2008

Co-author, “Funds May Need to Reconsider Tax Treatment of Management Fees,” Corporate Advisory, July 21, 2008

“Murphy v. IRS: Taxation of Personal Injury Awards,” The Practical Tax Lawyer, Winter 2008