Paul S. Manning is the Principal-in-Charge of KPMG’s Practice, Procedure, & Administration group in Washington National Tax, responsible for technical analysis and issue development related to federal tax practice, procedure, and administration.

His client work includes complex tax planning, technical and procedural matters, administrative tax controversy, and tax compliance and disclosures. Paul has extensive experience in administrative tax controversy matters in international tax, including foreign tax credit, structured transactions, sourcing, Subpart F, transfer pricing, FSC/DISC, effectively connected income, withholding, worthless stock and bad debt, and reportable transactions. He also has worked on several matters involving issues of business purpose and economic substance. 

Paul began his career at the IRS in the Office of Associate Chief Counsel (International), working predominately on large, international tax litigation matters. As an IRS National Office attorney assigned to monitor and coordinate significant litigation matters, he was involved in complex factual and international technical legal issues, as well as practice and procedure strategies at the pre-audit, audit, appeals, and litigation levels.

Paul served as trial counsel in two cases before the United States Tax Court, and also was trial counsel in two highly significant foreign tax credit case: Riggs National Corporation v. Commissioner, and Amoco Corporation v. Commissioner. In 1995, he received the Office of Chief Counsel’s Team Litigation Award for exceptional performance in the Amoco litigation.