Matthew Stevens, a partner in the International Tax Group, advises clients on a wide range of tax-related issues. He handles planning and controversy matters regarding the U.S. federal income tax consequences of transactions, specializing in the design, structuring and implementation of domestic and international financial transactions, including structures involving life settlement transactions, swaps, options, forward contracts, and all types of debt instruments (including hybrid debt, contingent convertible debt, and bond-hedge transactions). Matthew has substantial experience in international tax issues involving foreign tax credits, Subpart F and PFICs, withholding taxes, dual consolidated losses, hybrid and reverse hybrid entities and tax treaties. Based on this substantive knowledge base, he advises commercial banks, hedge funds, high net worth individuals (both U.S. and non-U.S.) and foreign and domestic multinational corporations.

From 2002 to 2004, Matthew served as special counsel to the Chief Counsel for the Internal Revenue Service.

Matthew Stevens, a partner in the International Tax Group, advises clients on a wide range of tax-related issues. He handles planning and controversy matters regarding the U.S. federal income tax consequences of transactions, specializing in the design, structuring and implementation of domestic and international financial transactions, including structures involving life settlement transactions, swaps, options, forward contracts, and all types of debt instruments (including hybrid debt, contingent convertible debt, and bond-hedge transactions). Matthew has substantial experience in international tax issues involving foreign tax credits, Subpart F and PFICs, withholding taxes, dual consolidated losses, hybrid and reverse hybrid entities and tax treaties. Based on this substantive knowledge base, he advises commercial banks, hedge funds, high net worth individuals (both U.S. and non-U.S.) and foreign and domestic multinational corporations.

From 2002 to 2004, Matthew served as special counsel to the Chief Counsel for the Internal Revenue Service. He advised the Chief Counsel regarding published guidance including regulations, revenue rulings and notices involving contingent convertible debt instruments, prepaid forward contracts, debt-forward contract units, partnership options and notional principal contracts.

Matthew serves as chair of the Practising Law Institute program “Taxation of Financial Products and Transactions” which is held semi-annually in both New York City and San Francisco. He serves as chair of the Financial Transactions Committee of the Tax Section of the District of Columbia Bar, and a vice chair of the Financial Transactions Committee of the Tax Section of the American Bar Association. He co-teaches the Georgetown University Law Center class entitled “United States Taxation of International Income – II.” He has published a number of articles dealing with international aspects of U.S. income tax and with the taxation of financial products and transactions. Matthew is listed in Chambers USA: America’s Leading Lawyers for Business.