Leighanne Scott is a Member and leader of the firm’s State & Local tax practice group. Within her practice, Ms. Scott represents individuals and multistate businesses on all aspects of state tax planning and controversies related to business operations, transactions, and personal income tax. She regularly provides counsel on technical issues involving federal conformity, nexus, apportionment, unity, partnership withholding, mergers and acquisitions, sales and use, business activity and real estate transfer taxes.
An integral part of Ms. Scott’s practice is her specialty in representing clients in state tax controversy at all levels of dispute including notice response, audits, administrative appeals and litigation. She frequently provides counsel to clients on voluntary disclosures, amnesty, and compliance initiatives as part of the controversy practice.
Recent examples of Ms. Scott’s work include:
- Representation of a real estate fund before the New York City Department of Finance to address application of real estate exemption to New York rental activity
- Acquisition due diligence services including successor liability matters, real estate transfer taxes, structuring, liability mitigation post-close and negotiation of state tax provisions within purchase and sale agreements
- Transaction assistance related to divestiture of realty in District of Columbia including application of liquidation exemption
- Analysis of state response to Federal Qualified Opportunity Zone initiatives
- Negotiation of favorable settlement with state taxing authority reducing sales tax assessment under appeal from $6M to $1M
- Advising clients on state planning opportunities based on Federal tax reform, including state response to IRC Sec. 965, GILTI, and FDII
- Assistance to non-US taxpayers with recommendations on state tax consequences of US operations
- Counsel to pass through entities regarding nonresident withholding obligations and examination of unitary presence within tiered partnership structures
- Provision of guidance regarding sales taxability of information services and data processing
- Representation of individual and business clients during state tax examination proceedings from desk audit through appeals
- Preparation and submission of state private letter rulings and voluntary disclosure agreements with taxpayer favorable results
Ms.Scott is a frequent speaker on state tax matters for Tax Executives Institute (TEI), participates in American University’s State Tax Roundtable, and has guest lectured at Georgetown University on Special Topics in State Tax.
Prior to joining the firm, Ms. Scott was a Tax Managing Director at a Big Four accounting firm where she specialized in income and sales tax planning and controversy.
Speaking Engagements
- Panelist, Federal Limitations on State Taxation: Charitable Contributions, PL86-272 and Others, Federal Bar Association, 44th Annual Tax Law Conference, March 6, 2020
- Speaker, Dreaded Reserves - ASC 450 in a Wayfair Landscape, COST Sales Tax Conference, February 26, 2020
- Speaker, Not GILTI - An Overview of GILTI - Federal and State - Exclusions, Marcus Evans, Tax Officers Summit, November 8, 2019
Click here for a full list of speaking engagements.
Recent Publications
- "IRS Kicks Off Post-Altera Audit Adjustments,"
with J. Clark Armitage, Charles M. Ruchelman, and Elizabeth J. Stevens, Caplin & Drysdale Client Alert, September 21, 2020
- "September 15th Deadline for Taxpayer Participation in North Carolina Transfer Pricing Resolution Initiative,"
with J. Clark Armitage, Caplin & Drysdale Client Alert, August 24, 2020
- "SALT Considerations in the Time of COVID-19,"
Caplin & Drysdale Client Alert, April 2, 2020
- "Maryland General Assembly Votes to Adopt Digital Advertising Gross Revenue Tax & Expand Sales Tax to Digital Products,"
Caplin & Drysdale Client Alert, March 20, 2020
- "INSIGHT: 2020 Vision for State and Local Tax,"
Bloomberg Tax: Daily Tax Report, December 27, 2019
Click here for a full list of publications.