Professional Experience
Matthew E. Foreman co-chairs FRB’s Taxation Practice Group and advises businesses on the tax effects of a variety of corporate transactions, including taxable and tax-free reorganizations, mergers, sales, and acquisitions. He designs and implements tax-efficient structures for U.S.-based businesses to expand abroad and invest in foreign joint ventures. Matt drafts 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. He defends clients from audits from the IRS and various state tax agencies, including appealing audit determinations. Matt advises 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). He drafts tax portions of Operating and Shareholder Agreements for businesses in different industries. Matt has extensive experience in a variety of SALT issues, especially New York State residency audits and state Sales and Use tax nexus issues post-Wayfair.
Matt started his career at Big 4 accounting firms where he advised Fortune 500 companies on a variety of tax matters. He is active in the New York City Bar Association, where he is the Secretary of the State and Local Tax Committee, as well as a Member of the Task Force on Digital Technologies and the Emerging Companies and Venture Capital Committee. He volunteers as a Helpline Volunteer with Savvy Ladies, a 501(c)(3) non-profit organization that brings financial planning education to women.
Matt also hosts FRB’s podcast How Tax Works, where he unravels the complexities of tax law.
Education
- New York University School of Law, Master of Laws, Taxation
- Penn State Dickinson School of Law, J.D.
- State University of New York at Albany, B.S., Business Administration, concentration in Finance, cum laude
Bar Admissions
- State of New York
- State of New Jersey
- United States Tax Court
Professional Affiliations
- New York City Bar Association, Secretary, State and Local Tax Committee; Member, Emerging Companies and Venture Capital Committee; Member, Task Force on Digital Technologies
- New York State Bar Association, Tax Section
- Savvy Ladies, Inc., a 501(c)(3) non-profit organization that brings financial planning education to women, Helpline Volunteer
Honors & Awards
- Selected to New York Metro Super Lawyers: 2020-2024; Selected to New York Metro Super Lawyers Rising Stars: 2018-2019
Related Publications
- Tax Issues with Divorce
- At Risk Limitations under IRC 465
- Passive Activity Losses and Credit Limitations under IRC 469
- Falcon Rappaport & Berkman Ranked in Chambers Regional Spotlight 2025
- Self-employment Tax on Partners, Net Investment Income Tax, and Soroban Capital Partners LP v. Comm’r (Part II)
- Self-employment Tax on Partners, Net Investment Income Tax, and Soroban Capital Partners LP v. Comm’r (Part I)
- Twenty-Three FRB Attorneys Selected to 2024 New York Metro Super Lawyers and Rising Stars List
- No Tax on Tips: Pragmatic Tax Proposal or Populist Tax Policy Nightmare?
- Tax Consequences of Forming, Selling, and Dissolving Partnerships and Disregarded Entities (Rev. Ruls. 99-5 and 99-6)
- Various State and Local Income Tax Issues
- Convertible Debt and SAFEs
- Profits Interests, Promotes, and How to Structure Equity-based Compensation
- Navigating Crypto Taxes with Matthew Foreman of How Tax Works
- Deductibility of Cryptocurrency Losses: Active Trade or Business Analysis
- Equity-based Compensation and 83(b) Elections
- Ordinary & Necessary Business Expenses: Examples and What Not to Do
- Ordinary & Necessary Business Expenses: IRC 162 and 212
- Navigating IRS Penalties: The Impact of Farhy v. Commissioner on U.S. Taxpayers
- Residency
- Sales and Use Tax
- Entity Selection
- Cannabis Rescheduling – A Look Towards the Future of the Industry
- For Tax Purposes, Are Limited Partners Really Limited Partners?
- IRS Announces Audits of Business Jet Usage as Part of Larger Effort to Target High-Income Taxpayers
- FRB Expands Taxation Practice Group, Elevates Andrew Gradman and Matthew Foreman to Co-Chairs
- Digital Assets Reporting Requirements Under Section 6050I
- IRS Announces Voluntary Disclosure Program for Employee Retention Credit (ERC)
- Initial Tax Relief for NYC Cannabis Businesses – Is More to Come?
- Employee Retention Credit Alert: Navigating the IRS’s New Withdrawal Process
- Fourteen FRB Attorneys Selected to 2023 New York Metro Super Lawyers and Rising Stars List
- Treasury and IRS Propose Regulations Requiring Brokers to Report Exchanges of Digital Assets and Withholding on Certain Payments
- IRS Clarifies the Tax Treatment for Proof of Staking Validation Rewards