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).