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Matthew A. Stevens

Partner


Matthew Stevens, a partner in the Federal and International Tax Group, advises commercial banks, hedge funds, high net worth individuals (both U.S. and non-U.S.) and foreign and domestic multinational corporations on a wide range of tax-related issues involving cross-border investments and financial transactions. In the area of outbound investment by U.S. persons, Matthew has advised clients regarding the restructuring of investments to eliminate PFIC or CFC status, to defer gain, accelerate loss and maximize interest deductions and foreign tax credits. On the inbound side, Matthew has advised non-U.S. clients regarding the minimization of U.S. income and withholding tax through the use of debt, total return swaps and other financial products, financial intermediary structures, and tax treaties. Matthew also has extensive experience in a variety of domestic financing transactions, including structures involving swaps, options, forward contracts and all types of debt instruments (including hybrid debt, contingent convertible debt and bond-hedge transactions).

Representative Experience

  • Represented numerous issuers in convertible bond–warrant transactions that resulted in substantial tax deductions, which were recently approved by IRS National Office.
  • Represented a major U.S. manufacturer on issuance of linked debt-equity units, and on the subsequent repurchase of such units.
  • Issued opinion to a non-U.S. fund regarding U.S. tax consequences of entering into total return equity swaps over master limited partnership interests.
  • Filed an amicus brief in Third Circuit in a major case involving tax advantaged international financing transaction.
  • Advised several taxpayers regarding Basket C and Basket D hybrid financing transactions, which made available substantial interest deductions and favorable rating agency treatment.
  • Advised a life settlement provider regarding investment by non-U.S. investors in a Luxembourg investment vehicle.
  • Advised a life settlement provider regarding establishing a tax-efficient blocker corporation for investment in life settlement transactions.
  • Advised dual citizens regarding restructuring of a minority stake in a European business.
  • Advised a U.S. multinational corporation regarding tax consequences under Section 987 of a complex intercompany reorganization prior to spin-off.
  • Advised a major investment advisor on a tax-advantaged partnership structure.
  • Advised a major financial services provider in establishing a platform for issuing rated securities backed by hedge fund loans.


Publications
April 9, 2011
“Some Thoughts Regarding the Granting of Discretionary Relief by the US ‘Competent Authority’ Under the Limitation on Benefits Provision of a Tax Treat,” Internationales Steurrecht, April 9, 2011.
2011
April 2008

Matthew A. Stevens

The Atlantic Building
950 F Street, NW
Washington, D.C. 20004-1404
Phone: 202-239-3553
Fax: 202-654-4923

Education

  • Harvard University
    (J.D., 1990)
  • University of Kansas
    (B.A., 1987)

Admitted to Practice

  • District of Columbia