Tax: Controversy (Band 4)
Practice Areas: Consistently recognized by Chambers, Scott Stewart’s practice focuses exclusively on tax disputes and transfer pricing matters. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals, and litigation before the United States Tax Court. His transfer pricing litigation experience includes a number of the landmark cases of the last two decades, such as National Semiconductor, Seagate Technology, Nestlé Holdings and United Parcel Service. Recently, Scott has focused particular attention on issues concerning deductibility of interest expense in related party transactions, including debt-versus-equity characterization and sham transaction and economic substance issues.