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Scott M. Dayan

Scott Dayan focuses his practice on international tax planning for businesses, as well as in the handling of large case tax controversies with the Internal Revenue Service (IRS), including audit, appeals and litigation.

Mr. Dayan was recognized by The Best Lawyers in America® for Tax in 2011 and the four years immediately preceding. He is listed in the 2009 and 2010 editions of Chambers USA: America’s Leading Lawyers for Business and was named a Georgia “Super Lawyer” in Tax Law by SuperLawyers magazine in 2010 and the four years preceding. Mr. Dayan was also recognized in The International Who’s Who of Business Lawyers for 2009. Mr. Dayan previously served as a law clerk to Judge William Fay of the United States Tax Court.

Experience Highlights

• IRS challenging a listed transaction for an aerospace manufacturer
  Mr. Dayan served as lead counsel in the representation of a leading aerospace systems supplier in a case involving a “listed transaction” being challenged by the IRS. The listed transaction at issue involved claiming deductions for contributions to its 401k plans prior to the year that the employees performed the services. Upon filing of a Motion for Partial Summary Judgment asking the Tax Court to dismiss the IRS’s proposed deficiencies relating to the 401k deductions, the IRS agreed to concede the entire case, dropping its proposed assessments of tax and penalties.

• Tax counsel to multinational hotel chain regarding cross-border dividend payment
  Tax counsel to multinational hotel chain in procuring an IRS private letter ruling regarding the application of the U.S.-Netherlands treaty to a significant dividend payment.

• Tax counsel to a large wholesaler regarding IRS examination of acquisition
  Represented a large wholesale of contracting supplies and materials (owned by private equity firms) at IRS Examination and IRS Appeals regarding deductions for an array of acquisition-related expenses, including attempts to settle the case through Fast Track Mediation procedures.

• Tax advice for a multinational chemical corporation
  Mr. Dayan serves as regular tax advisor to a multinational chemical corporation based in the Netherlands with operations in 60 countries.

Professional & Community Activities

• Vice President-Secretary, USA Branch of the International Fiscal Association
• Emory University School of Law, Former Adjunct Professor of Tax Law
• ABA Section of Taxation, Foreign Activities of U.S. Taxpayers Committee