E. Christenson

Erik J. Christenson

Partner
Baker & McKenzie LLP

Biography

Erik Christenson practices in the area of general international tax planning for businesses.

Practice Focus

Erik's practice focuses on advising multinational corporations — both US and foreign-based — on all aspects of the taxation of international structures and cross-border transactions and operations. He represents clients in various industries, including online services and e-commerce, software, payments and fintech, and life sciences.

Erik is the liaison to the Global Tax Practice Group for the Technology Media and Telecom Industry Group, and he is a member of the leadership team reporting to the Global Tax Practice Steering Committee. He is a charter member of the Baker & McKenzie Antiracism Taskforce and he sits on the Diversity and Inclusion Committee for the California offices.

Representative Legal Matters

  • Advised on restructuring responses to domestic and international changes in tax law.

  • Implemented and restructured complex intellectual property arrangements, including US cost sharing and IP partnerships.

  • Developed strategies with respect to manufacturing practices and distribution supply chains.

  • Advised on tax aspects of cross-border merger and acquisition transactions.

  • Managed several large post-acquisition integrations and other legal entity restructurings through spin-offs, divestitures and joint ventures.

  • Developed strategies to repatriate foreign earnings or to borrow funds to meet US and non-US cash needs.

  • Developed solutions for a wide variety of other US and multijurisdictional international tax issues.

Professional Associations and Memberships

  • California State Bar Association
  • International Fiscal Association
  • American Bar Association

Admissions

  • California~United States (2001)

Education

  • University of California, Hastings College of the Law (J.D. cum laude) (2000)
  • Dartmouth College (B.A. cum laude) (1985)

Languages

  • English

Previous Offices

  • Palo Alto
  • Frequent speaker at Baker McKenzie seminars and workshops for clients and for internal audiences, as well as at external events sponsored by, among others, IFA and the Tax Executives Institute (TEI)

  • Co-author, "Foreign Income Portfolios: U.S. International Portfolios Taxation of U.S. Persons' Foreign Income | Portfolio 6360" Bloomberg Tax & Accounting, 2019

  • Co-author, "Foreign-Derived Intangible Income: Unanswered Questions on Foreign Use," Tax Management International Journal, 47 TM International Journal 240, 13 April 2018

  • Co-author, "An Introduction to The Complexities of Taxing Cross-Border Transfers of Digital Goods and Services," Florida Bar Journal, Vol. 92, No. 2, February 2018

  • Co-author, "Is 351 the New F? The IRS Revokes Rev. Rul. 78-130 and Blesses the Form of the 'Triple Drop and Check' in Rev. Rul. 2015-9 and Rev. Rul. 2015-10 (Aug. 19, 2015)," The Tax Magazine, Vol. 93, No. 9, September 2015