Matthew Lykken is Counsel in the firm’s Taxation practice group.  He has three decades of planning and audit experience in international corporate tax in the biopharma, medical manufacturing and petrochemical industries, including roles as global head of tax and regional director in both EMEA and Asia-Pacific.

REPRESENTATIVE EXPERIENCE

  • Designed and implemented principal-commissionaire structure with associated R&D cost sharing, which has cleared U.S. audit including audit under the new U.S. contract manufacturing regulations and has cleared the primary European audits.
  • Involvement and/or oversight in several acquisitions of technology companies and manufacturing companies, addressing U.S. and local tax issues and counterparty issues.
  • Involved in transfer pricing contemporaneous documentation implementation by outsourced provider and oversaw later insourcing of same.
  • Oversaw and advised on transfer pricing audits, APAs, and CA proceedings in various jurisdictions worldwide and implemented the most complex of the original Compliance Assurance Process audits.
  • Negotiated with Puerto Rican, Swiss, and Singaporean authorities regarding tax incentive grants.
  • Implemented Sarbanes Oxley control processes and moved from an inherited broken process that was the subject of a material weakness and restatement to a leading process with multiple years of no deficiencies
  • Designed and implemented tax-efficient investment structure for high-risk operations.
  • Provided U.S./foreign tax support for three major ($l00MM+) financings and two major refinancings.
  • Evaluated tax-advantaged financing proposals from investment banks.
  • Provided U.S./foreign tax support for both wholly-owned and joint venture investments in exploration and chemical operations, in countries including Brazil, the Faeroe Islands, Hungary, Korea, the Netherlands, Norway, Poland, Turkey, and the UK.  

PREVIOUS EXPERIENCE

  • Baxter International, Vice President, Tax
  • Amoco Corporation/BP, Associate General Tax Counsel, Planning & Litigation
  • Internal Revenue Service, Field Attorney

PUBLICATIONS AND SPEECHES

Publications

  • Mrs. Logan Comes to a Sudden Realization: An Analysis of the Current State of the Open Transaction Doctrine, 42 Okla. L. Rev. 581 (1989)
  • “Sharing Economic Growth,” 114 Tax Notes 691 (Feb. 12, 2007) and 45 Tax Notes Int’l 865 (March 5, 2007)
  • “Shared Economic Growth: A Proposal for Tax Reform,” 118 Tax Notes 1221 (March 12, 2008)
  • “The GAO Analysis on Multinational Corporations: Trial by Innuendo,” 51 Tax Notes Int’l 1031 (September 22, 2008)
  • It’s Not That Difficult: The Shared Economic Growth Solution to Tax Reform (publication pending in Pace Law Review)

Speeches

  • Getting the Best From a Centralized or Decentralized Tax Function at Euroforum seminar on Best Practices for Global Tax Management in Multinationals, London, 1996.
  • Presented a business perspective on transfer pricing at Chinese State Administration for Taxation national training for all transfer price auditors in Xian, 2009.
  • Presented at TEI and MAPI on multiple occasions on audit and policy related topics.

Education

  • Harvard Law School, J.D., 1985
    cum laude
  • University of Minnesota, B.A., 1980

Practice Areas

Taxation

Admissions

  • Texas
  • United States Tax Court