Mayer Brown LLP: Stewart Scott M

For businesses and corporations navigating the intricate landscape of federal tax law, the challenges can be immense. Whether facing a rigorous IRS audit, engaging in complex administrative appeals, or preparing for high-stakes tax litigation, the need for exceptional legal counsel is paramount. For entities operating in Illinois and across the globe, Mayer Brown LLP, and particularly attorney Scott M. Stewart, offers unparalleled expertise in tax controversy and transfer pricing matters.

Scott M. Stewart, a distinguished partner at Mayer Brown LLP, has dedicated his practice to exclusively representing taxpayers in tax disputes and transfer pricing issues. His extensive experience spans all levels of federal tax controversy, from initial audits and administrative appeals before the Internal Revenue Service to complex litigation before the United States Tax Court. Mr. Stewart is widely recognized for his strategic acumen, deep understanding of intricate tax issues, and ability to effectively communicate complex legal concepts to clients and judges alike.

Operating within the framework of a global law firm like Mayer Brown LLP, Mr. Stewart leverages vast resources and a collaborative approach to deliver comprehensive solutions for his corporate clients. For Illinois-based businesses, this means having direct access to a nationally recognized expert right in Chicago, equipped to handle the most challenging tax disputes, both domestically and internationally. When your business faces a significant tax challenge, the proven track record and sophisticated expertise of Scott M. Stewart at Mayer Brown LLP can be a critical asset in protecting your financial interests and securing favorable resolutions.

Mayer Brown LLP, where Scott M. Stewart practices, is prominently located at 71 S Wacker Dr, Chicago, IL 60606, USA. This address places the firm in the vibrant heart of Chicago's Loop, a central business and legal district within Illinois. For corporate clients, this location offers exceptional convenience and accessibility in a major urban center.

The office building on South Wacker Drive is easily accessible through Chicago's extensive public transportation network. Numerous CTA 'L' train lines (including the Brown, Orange, Pink, Purple, Green, and Blue lines) and various bus routes have stops within a short walking distance of the firm's premises. This connectivity ensures that clients and professionals from across Chicago and its wider metropolitan area can reach the office efficiently. While downtown Chicago offers numerous paid parking garages for those driving, the robust public transit options provide a viable alternative.

Being situated in such a pivotal and accessible location allows Mayer Brown LLP to effectively serve a broad spectrum of corporate clients, ranging from large multinational corporations to significant Illinois-based enterprises. The firm's presence in a leading financial and legal hub like Chicago underscores its capacity to handle complex and high-value tax matters for a diverse client base.

Scott M. Stewart's practice at Mayer Brown LLP is exclusively dedicated to complex tax disputes and transfer pricing matters for corporate clients. His specialized expertise covers a wide array of services essential for businesses navigating challenging tax environments. Based on available public information, his key areas of service include:

• Federal Tax Controversy & Litigation:
  • Representing taxpayers at all levels of federal tax controversy, from initial audits to administrative appeals before the Internal Revenue Service (IRS).
  • Litigation before the United States Tax Court, addressing high-stakes and complex federal income tax issues.
  • Involvement in significant cases concerning the deductibility of interest expense in related-party transactions, including debt-versus-equity characterization, "sham transaction," and "economic substance" issues (e.g., his involvement in the landmark Nestlé Holdings case).
  • Leading teams in filing Tax Court petitions concerning substantial debt-equity issues.
• International Transfer Pricing:
  • Extensive experience in all aspects of international transfer pricing, which involves the pricing of goods, services, and intellectual property transferred between related entities in different countries.
  • Advising on cross-border movements of tangible and intangible property.
  • Expertise in Advance Pricing Agreements (APAs), which are agreements between a taxpayer and tax authorities regarding the pricing of future related-party transactions.
  • Counsels on Cost Sharing Arrangements and Section 6662 documentation (transfer pricing penalty defense).
  • Handling transfer pricing litigation, including major cases of the last two decades (e.g., National Semiconductor, Seagate Technology, Nestlé Holdings, and United Parcel Service).
• IRS Administrative Proceedings:
  • Representation during IRS examinations and various administrative dispute resolution proceedings.
  • Mediation involving the Appeals division of the IRS.
  • Competent authority issues and negotiations related to tax treaties.
• Acquisition-Related Tax Issues:
  • Advising on tax matters arising from mergers and acquisitions, including the valuation of tangible and intangible assets.
• Civil and Criminal Tax Penalties:
  • Providing counsel on issues related to civil and criminal tax penalties.
• Tax Accounting Matters:
  • Advising on accounting for tax matters under FIN 48 of the Financial Accounting Standards Board.

Scott M. Stewart's practice at Mayer Brown LLP is distinguished by several key features and highlights that underscore his prominent standing and effectiveness in the field of tax law:

• Exclusive Focus on Tax Disputes and Transfer Pricing: His practice is solely dedicated to these highly specialized areas, indicating a deep, concentrated expertise that is invaluable for corporate clients facing complex tax challenges.
• Decades of Experience: Having joined Mayer Brown in 1989, Scott Stewart brings a wealth of experience, spanning over three decades, in navigating and resolving intricate federal tax controversies.
• Recognized Industry Leader: He has been consistently recognized by prestigious legal publications like Chambers USA for his skills as a "talented litigator and corporate advisor," praised for his "extraordinary communication skills" and "broad and deep experience."
• Exceptional Judgment and Analysis: Clients and peers recommend him for his "spot-on judgment and analysis" and his responsiveness, highlighting his ability to provide insightful and practical legal counsel.
• Extensive Litigation Track Record: Mr. Stewart has led successful litigation efforts in major tax cases before the United States Tax Court, including landmark cases involving significant financial stakes, such as the Nestlé Holdings case and matters for Tyco International.
• Mastery of Complex Tax Issues: His expertise covers the most challenging aspects of tax law, including debt-versus-equity characterization, "sham transaction" and "economic substance" issues, and all facets of international transfer pricing.
• Leadership Role: As a co-leader of Mayer Brown's Tax Controversy and Transfer Pricing practice, he plays a pivotal role in shaping the firm's strategy and capabilities in these critical areas.
• Comprehensive Administrative Dispute Resolution Experience: Beyond litigation, he is highly experienced in various IRS administrative proceedings, including audits, Appeals mediation, and competent authority negotiations, offering clients diverse avenues for dispute resolution.

For large corporate clients engaging with a global law firm like Mayer Brown LLP, particularly for highly specialized tax controversy and international tax matters, standard "promotions or special offers" in the consumer sense are not typically provided. The value proposition for services rendered by attorneys like Scott M. Stewart is based on their unparalleled expertise, strategic guidance, and proven ability to navigate and favorably resolve complex, high-stakes tax disputes. These are premium legal services for significant corporate issues.

Instead, the firm's engagement terms are generally tailored to the specific needs and complexity of the client's case. This often involves:

• Customized Fee Structures: These can include hourly rates for advisory work, project-based fees for defined engagements, or specific arrangements for litigation that are determined based on the scope, duration, and potential financial impact of the matter.
• Value-Based Outcomes: The focus is on the long-term value delivered, such as mitigating substantial tax liabilities, achieving favorable settlements, or securing successful litigation outcomes, which can save companies millions or even billions of dollars.

Prospective corporate clients interested in retaining Scott M. Stewart or the tax team at Mayer Brown LLP would typically initiate contact for a detailed consultation. During this consultation, discussions would cover the specific tax challenges the client faces, the firm's proposed strategy, and a comprehensive outline of the expected legal fees and engagement terms. This transparent approach ensures that clients fully understand the financial commitment involved before proceeding.

To connect with Scott M. Stewart at Mayer Brown LLP and discuss your complex tax controversy or transfer pricing needs, please use the following contact information:

Address: 71 S Wacker Dr, Chicago, IL 60606, USA

Phone: (312) 701-7821

Mobile Phone: +1 312-701-7821

Reaching out via phone is the most direct and efficient method to initiate contact. This will allow you to speak with a representative and arrange for a consultation with Scott M. Stewart or a member of his specialized tax team. Given the highly technical and significant nature of federal tax controversy and international tax matters, direct communication is crucial to convey the specifics of your situation and to understand how Mayer Brown LLP's extensive resources and Mr. Stewart's renowned expertise can be applied to your business's unique challenges. The firm's Chicago office is well-equipped to serve corporate clients both within Illinois and those with broader national or international tax concerns.

For corporate entities and businesses across Illinois, Mayer Brown LLP, specifically through the expertise of Scott M. Stewart, stands as an exceptionally suitable and vital legal resource for navigating the most challenging tax landscapes. While not a local neighborhood lawyer in the traditional sense, his presence in Chicago provides Illinois businesses with direct access to a globally recognized leader in tax controversy and transfer pricing – expertise that is often sought nationally and internationally.

The firm's strategic location in downtown Chicago ensures easy access for businesses located throughout the state, particularly those in the metropolitan area. What makes Mr. Stewart's practice especially suitable for locals is the unparalleled depth of experience and strategic acumen he brings to complex federal tax issues. Illinois businesses, whether large corporations or growing enterprises facing significant tax audits, disputes, or intricate international transactions, can benefit immensely from his proven track record in high-stakes litigation and administrative proceedings.

His specialized focus means that Illinois companies do not need to look beyond their state borders for top-tier legal representation when confronted with the most challenging tax issues, such as those involving billions in interest expense or complex international transfer pricing. For Illinois businesses prioritizing sophisticated, effective, and results-driven advocacy in their tax matters, engaging with Scott M. Stewart at Mayer Brown LLP offers a critical advantage in protecting their financial interests and ensuring compliance within an increasingly complex global tax environment.