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Matthew Dimon torso

Matthew L. Dimon

Associate
Tax

Matthew advises a wide variety of clients, focusing on technology companies, funds, and the investors who back them, on U.S. federal income tax, with particular depth in partnership tax, international tax, and the taxation of digital assets. His practice spans transactional tax work, tax planning, and tax controversy.

Matthew is proud to be part of Fenwick’s cutting-edge blockchain tax practice, where he advises and writes on digital asset taxation, including the treatment of staking rewards and liquid staking tokens, protocol upgrades and forks, and the application of longstanding realization and income principles to on-chain activity. His work in the area has appeared in Tax Notes and other tax publications.  Matthew has participated in discussions with officials at the Treasury Department, the Internal Revenue Service, and Congressional offices on the development of U.S. digital asset tax guidance. He has also engaged with policymakers outside the United States on matters relating to digital asset taxation, including at the OECD, the U.K. House of Lords, and the Cayman Islands Ministry of Finance.

In his partnership tax practice, Matthew handles fund and joint venture formation, and partner-level economic arrangements. He frequently works with clients on bespoke partnership structures.

On the tax planning and transactional side, Matthew frequently advises on complex inbound and outbound structuring, transfer pricing, high-stakes M&A, and a wide variety of domestic tax matters. He has been deeply involved in tax planning relating to investment in both U.S. and foreign AI infrastructure.

Matthew’s controversy practice spans IRS examinations, Appeals, and Tax Court matters, frequently involving issues of first impression such as Rogovy. Matthew also has substantial experience with the BBA audit regime for partnerships.