Scott M. Stewart

International Tax & Transfer Pricing, Litigation & Dispute Resolution, Tax Transactions & Planning

"Frequently leads on market-defining transfer pricing disputes, often with multi-billion dollar outcomes."
Chambers USA


Since joining Mayer Brown in 1989, Scott Stewart’s practice has focused exclusively on tax disputes, including transfer pricing issues arising under I.R.C. §482 and intercompany debt matters arising under I.R.C. §385. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals before the Internal Revenue Service, litigation before the United States Tax Court, and competent authority proceedings, including advance pricing agreements.


  • Hyatt Hotels Corporation & Subsidiaries v. Commissioner of Internal Revenue, Tax Court Docket No. 13858-17 (tax consequences of customer loyalty program).
  • Tribune Media Company, f.k.a. Tribune Company & Affiliates, et al. v. Commissioner of Internal Revenue, Tax Court Docket Nos. 20940-16, 20941-16 (tax treatment of leveraged partnership transaction).
  • General Foods Credit Corporation v. Director, New Jersey Division of Taxation, Tax Court of New Jersey Docket No. 011703-15


  • Creighton University, BS, cum laude
  • Cornell University, MBA, with distinction (accounting & finance)
  • Harvard Law School, JD

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  • Illinois


  • US Tax Court