matthew-brown
Image of Matthew Brown

Matthew Brown

Counsel

Email

matthew.brown2@aoshearman.com

Phone

+1 202 508 8066

Offices

Washington DC

V-CARD

Matt focuses on a range of areas of tax law, with a particular focus on cross-border tax issues and the tax aspects of corporate and partnership transactions.

Matt’s practice includes U.S. domestic and international tax planning and transactional work, including issues relating to mergers and acquisitions, joint ventures, private equity and hedge fund investments, controlled foreign corporations and passive foreign investment companies, and Pillar Two, as well as the taxation of financial instruments and various financing transactions. He also advises multinational corporations with respect to corporate, partnership and international tax matters and strategic restructurings. Matt represents corporate, financial institution, private equity and sovereign wealth fund clients.

Expertise

Industries

Experience

Representative matters

  • Circet USA, a subsidiary of Circet Holdings SAS, in various acquisitions.
  • Celanese Corporation in the food ingredients joint venture with Mitsui & Co.
  • Mubadala in the acquisition, together with Fortress management, of Fortress Investment Group from Softbank Group Corp.
  • Celanese Corporation in the restructuring of its 50/50 Korea Engineering Plastics Co. joint venture with Mitsubishi Gas Chemical Company, Inc. and various internal restructuring transactions.
  • Glatfelter Corporation in its $308 million acquisition of the Jacob Holm Group.
  • Paramount Global in various transactions, including its $1.62 billion sale of Simon & Schuster to KKR.
  • Société Générale on its joint venture with AllianceBernstein.
  • Anglo American plc in connection with the business combination between its nuGenTM Zero Emissions Haulage Solution and First Mode Holdings, Inc.
  • The Energy and Minerals Group (EMG) and Vision Blue Resources in their investment in Serra Verde, a Denham Capital portfolio company, that is developing an integrated rare earth element mining and processing operation in Brazil.
  • MDH Acquisition Corp. in connection with its $960 million de-SPAC transaction with Paylink Direct and Olive.com.
  • Amyris, Inc. in its acquisition of Olika Inc.

Published Work

  • "Interest Equivalents Are Out Under the 163(j) Regulations! Or Are They?", Tax'n Fin. Prod., 2021
  • "Most Thought §961(c) Was on the Sidelines During TCJA", Tax Mgm't Int'l J., 2020
  • "The Odd Couple: Code Sec. 305(c) and Make-Whole Fundamental Changes", Tax'n Fin. Prod., 2019

 

Speaking Engagements

  • "What Makes a Foreign Tax Creditable", presented during the Florida Bar Tax Section 2023 Organizational Meeting (July 2023)
  • "Pillar Two, U.S. Multinational Enterprises and Legislative Inaction", panelist during the ABA Section of Taxation 2022 Fall Tax Meeting (October 2022)
  • "How Things Are Going 'SOFR': Final LIBOR Regulations", panelist for D.C. Bar Tax Community Financial Products Committee Meeting (February 2022) 

Leadership Positions And Professional Affiliations

  • American Bar Association Tax Section
  • Florida Bar Tax Section
  • D.C. Bar Association Tax Section, Vice Chair of Financial Products Committee

Qualifications

Admissions

Attorney-at-Law, D.C.

Attorney-at-Law, Florida

Courts

United States Tax Court

Academic

Ave Maria School of Law J.D., magna cum laude

Editor-in-Chief, Ave Maria Law Review

New York University School of Law LL.M.

University of Florida B.S., cum laude

Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.