Matthew Foreman

About Matthew Foreman

I advise businesses on the tax effects of a variety of corporate transactions, including taxable and tax-free reorganizations, mergers, sales, and acquisitions. I design and implements tax-efficient structures for U.S-based businesses to expand abroad and invest in foreign joint ventures. I draft tax memoranda and opinions on a variety of subjects, including tax-free reorganizations, tax-efficient return of capital to owners, Qualified Small Business stock, and various state pass-through entity taxes. I defend clients from audits from the IRS and various state tax agencies, including appealing audit determinations. I advise clients on a variety of tax issues related to cryptocurrencies, including initial coin offerings (ICOs), taxability of staking and air drops, and the imposition of Sales and Use taxes on the issuance of non-fungible tokens (NFTs). I draft tax portions of Operating and Shareholder Agreements for businesses in different industries. I have extensive experience in a variety of SALT issues, especially New York State residency audits and state Sales and Use tax nexus issues post-Wayfair.

Experience

1. Partner, Co-chair Tax Group

   Falcon Rappaport & Berkman LLP

   Jul 2023 — Present · New York, NY, US

Education

• University at Albany

  Bachelors of Science (Cum Laude), Business Administration, Finance

  2000 — 2004

• Penn State Dickinson Law

  Juris Doctor, Law, Taxation

  2004 — 2007

• New York University School of Law

  Master of Laws (LL.M.), Taxation

  2014 — 2015