Experience
Stewart is an experienced private client lawyer with a particular specialism in international taxation.
In addition to carrying out tax advisory engagements on behalf of offshore fiduciary services providers and banks, he has developed Excel tools to assist with carrying out exercises to quantify the “pools” of foreign income and gains sitting within legacy offshore structures, which are typically required ahead of trustees making distributions to UK resident beneficiaries and with the aim of assisting the UK beneficiaries with their UK tax reporting. On the same theme of “compliance-driven tax advisory” engagements, he has since the changes to the UK’s non-dom tax regime took effect from April 2025, developed a further set of Excel tools to assist with the analysis of “mixed fund” accounts to ascertain the cost of “cleaning up” mixed fund accounts under the UK’s temporary repatriation facility (TRF).
He has particular experience dealing with HMRC enquiries and regularising historic tax issues through voluntary disclosures, in particular, working within the parameters of HMRC’s online disclosure facilities. A recent project involved the preparation and co-ordination of disclosures on behalf of the shareholders of an independent fund management company.
Memberships
- Society of Trust & Estate Practitioners (STEP)