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Matthew Brown


Matthew Brown is an associate in the Tax practice. He focuses on a range of areas of tax law.

His practice includes 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, the taxation of financial instruments and a variety of capital markets and financing transactions. He also has experience advising multinational corporations with respect to corporate tax matters and strategic restructurings. Matthew represents corporate, financial institution and sovereign wealth fund clients.



Representative matters

Paramount Global on the pending sale of Simon & Schuster to KKR for $1.62 billion.

Celanese Corporation in the pending food ingredients joint venture with Mitsui & Co.

Mubadala in the pending 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.

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
  • New York State Bar Association Tax Section



Attorney-at-Law, D.C.

Attorney-at-Law, Florida


United States Tax Court


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

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.