Co-Chair of the firm's International Taxation & Wealth Planning Practice, Scott focuses his practice on international tax planning and wealth management for high-net-worth individuals.

He handles a full range of international taxation and wealth issues, including:

• A wide variety of international tax planning matters primarily related to the representation of high-net-worth and ultra-high-net-worth international private clients.
• Draft sophisticated foreign and domestic trust agreements and advise clients regarding all aspects of international wealth-succession and pre-immigration tax planning (including matters related to the U.S. taxation of foreign trusts, foreign foundations, U.S. estate and gift tax rules as applicable to non-citizen, non-resident alien domiciliaries, and the U.S. taxation of U.S. beneficiaries of foreign trusts).
• Structure private equity funds and hedge funds with foreign investors and foreign sponsors to create tax efficient investment structures.
• Draft sophisticated operating and limited partnership agreements for real estate funds that include provisions involving waterfall distributions with various hurdle rates in accordance with regulatory allocations.
• Prepare and file Delinquent Information Return Procedures, Delinquent FBAR Procedures, Foreign Streamline Procedures and Domestic Streamline Procedures for U.S. tax residents to become compliant with their failure to file international information returns.
• Advise clients regarding inbound tax planning including planning for the use of U.S. tax treaties, establishing portfolio interest investment structures, and creating tax-efficient U.S. real property investment structures considering FIRPTA and estate tax laws, tax-free reorganizations with U.S. corporations.
• Advise clients regarding outbound tax planning including planning for the use of U.S. tax treaties, Subpart F planning, transition tax, FDII, GILTI, foreign tax credits, participation exemption, and PFICs.
• FIRPTA planning including tax-free corporate reorganizations in the context of § 897 and post-mortem planning related to corporate ownership of U.S. real property.
• Pre-immigration tax planning including drafting drop off trusts and reorganizing U.S. and non-U.S. investments.
• Expatriation tax planning including analysis regarding whether someone qualifies as a covered expatriate and reducing the application of the exit tax.
• International estate planning involving the use of foreign corporations to block U.S. estate tax, foreign grantor trust planning, post-mortem trust administration, and PFIC planning in the administration context.