Matthew McKim leads the International Private Client Group.
As an international tax lawyer, he primarily counsels his clients on a wide range of US and non-US tax planning matters. Matt’s clients range from entrepreneurs wishing to establish a family office, to established global families managing their own wealth in the multibillions, to some of the world’s most renowned trust companies. Matt has extensive experience with a wide range of global family structures and common issues and prides himself on delivering efficient, strategic and results-oriented solutions for his clients.
He regularly assists clients (most often multinationals and their families) in navigating the United States legal system, generally from a tax perspective, but also with respect to the various other considerations which arise when families (or select family members) move to, or invest in, the United States. Matt has been referred to by his clients as their “global quarterback”, wherein he works with families to identify legal considerations (tax and non-tax alike) and provide solutions that are tax-efficient in nature but most importantly capture the client’s business needs and family succession considerations. Matt is versatile and resolute on delivering innovative, yet practical, legal strategies.
Matt has significant experience in working with families in Latin American, Europe, Middle East and Africa, Hong Kong, Southeast Asia and, of course, the United States. He considers himself fortunate to work with some of the most successful businessmen, businesswomen, former politicians, professional athletes and celebrities in these regions and the trust companies and private banks that act for them. Matt, and those that work with him on the International Private Client team, are truly dedicated to their clients and it shows in the highly service oriented advice and product they deliver.
- Representation of numerous non-US families seeking to succeed assets to younger US generations in a tax-efficient manner (commonly referred to as “foreign grantor trust” planning) and all tax aspects that arise throughout the chronological stages of such planning, to include, significantly, managing all of the considerations (whether a current or future issue) of the “accumulation distribution” regime (DNI/UNI) and “controlled foreign corporations” and “passive foreign investment companies”.
- Representation of numerous non-US families immigrating to the United States and providing tax and family succession advice related to the various considerations which arise (commonly referred to as “pre-immigration planning”).
- Representation of numerous US families “expatriating” from the United States and ensuring that such a move is done in the most tax efficient manner possible (commonly referred to as “expatriation planning”).
- Representation on tax and other related legal considerations of numerous non-US families on the acquisition and ownership of various United States assets, to include private residences, commercial real estate, cars, boats, private planes and a variety of United States businesses (ranging in asset class, e.g., hospitality, media, logistics).
- Representation of families with respect to "institutionalization" of their wealth over multiple generations and jurisdictions, including establishment of private and licensed trust companies, family banks, and related structures facilitating the clients’ needs.
- Significant experience managing “global reporting” for multinational families, to include classification, registration and reporting under both the Foreign Account Tax Compliance Act (commonly known as “FATCA”) and the “Common Reporting Standard” (commonly known as “CRS”) but also to include advising on intergovernmental requests vis-à-vis various Tax Information Exchange Agreements with the United States as well as common US reporting for multinational families (e.g., Form 3520s, Form 8938s, Form 1040s / 1040NRs, foreign grantor and nongrantor trust beneficiary statements and the various other reporting obligations that arise when families enter the United States).
- Representation of a European based registered trust company’s rearrangement of its headquarters to the United States, establishment of a US trust company and development (i.e., strategy and implementation) of its US based product designed for LATAM families.
- Representation of non-US family in an acquisition of a majority stake in non-US consortium invested in a circa US$2 billion acquisition and redevelopment project of a trophy property in one of the top markets in the United States.
- Representation of US families investing outside of the United States and implementation of planning involving “controlled foreign corporations” and “passive foreign investment companies”.
- Representation of private equity and hedge funds organized in the Cayman Islands, Bahamas, Barbados and the British Virgin Islands in connection with acquisitions of US businesses and various other business issues, including the acquisition of multimillion-dollar funds and other restructurings.
- Representation of a private equity fund in connection with planning for an allocation of US$1 billion of cancellation of debt income and tax characterization issues regarding hedging transactions related to more than US$1 billion in allocable trading losses.
- Representation on tax structuring matters related to the formation of a German-based private equity raising US$1 billion to invest in seagoing cargo vessels having operational connections with US ports, specifically structured to utilize US tax laws to prevent the imposition of US tax on foreign investors.