I am a London-based U.S. lawyer specializing in U.S. federal and international taxation. My career spans over three decades across federal public service, international structured finance, law firms, and independent practice—complemented by four years of residency in France—giving me a broad perspective on how multi-jurisdictional tax law intersects with reality.

My practice focuses on complex tax treaties, international wealth structures, and federal tax controversy. I represent clients in disputes before U.S. tax authorities and federal courts, with a focus on transatlantic matters involving the United Kingdom, United States, France, Canada, and Europe.

Key Professional Pillars:

Treaty Controversy & Litigation: Counsel on international tax disputes, including the decade-long litigation against the IRS in Eshel v. Commissioner, which secured foreign tax credits for U.S. expats facing French social taxes (CSG/CRDS), and current work on the Net Investment Income Tax (NIIT) framework in Bruyea v. United States / Christensen v. United States.

Appellate Litigation: Practice in federal appellate strategy, rooted in early career experience within the Appellate Section of the United States Department of Justice (Tax Division) and a law clerk for the Washington State Supreme Court. 

Structured Finance & Commercial Experience: Ten years spent within boutique investment banks specializing in tax-structured finance, providing a clear understanding of the structured commercial and corporate transactions that tax authorities evaluate.

Academic Footprint: UC Berkeley Law graduate and Cambridge University LL.M. alumnus (Gonville & Caius College), maintaining a commitment to advancing the practical understanding of international tax doctrine.

Stuart also runs a dual qualified US/UK charity that allows UK resident US citizens to donate funds to charitable causes worldwide. In the twenty years that the charity has been in existence, it has raised over $50,000,000.