Stewart is a taxation lawyer with over 30 years’ experience specialising in taxation audits and disputes.
Stewart acts for major corporate clients in relation to the conduct of Australian Taxation Office audits and enquiries and resolution processes to bring such audits or enquiries to a conclusion.
Stewart’s taxation disputes practice is “end-to-end” which means that he advises clients on all aspects of:
Stewart lectures in the Master of Laws program at Melbourne University.
Acting for the Australian subsidiary of a major global information technology group in relation to an Australian Taxation Office audit of the subsidiary’s Australian operations.
Acting for an Australian subsidiary of a major global manufacturing group in relation to an Australian Taxation Office Large Business Audit.
From 1993 to present, advised Foster’s and its subsidiaries in relation to various Australian Taxation Office risk reviews and audits.
From 2012 to 2014, acted for a privately owned company in relation to an Australian Taxation Office audit.
From 2007 to 2011, acted for a number of Foster’s Group companies in Federal Court and Full Federal Court proceedings concerning the deductibility of bad debts and interest outgoings totalling approximately $2.8 billion.
In 2014, acted for the Law Institute of Victoria in relation to Supreme Court proceedings concerning the LIV’s payroll tax status.
The Full Federal Court has handed down its much-anticipated decision in PepsiCo, Inc v Commissioner of Taxation [2024] FCAFC 86, overturning the decision of the Federal Court.
The Commissioner of Taxation (Commissioner) has been actively pursuing the application of the anti-avoidance provisions to trust structures and trust distributions. In the most recent decision, the...
A single judge of the Federal Court has upheld a decision of the Commissioner of Taxation (Commissioner) to apply the general anti-avoidance rule, Part IVA, to arrangements that include the income...