E. Christenson

Erik J. Christenson

Baker & McKenzie LLP


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

Erik is a member of the steering committee for the Northern California chapter of the International Fiscal Association (IFA), and he is on the Permanent Scientific Committee for IFA USA. Erik is the liaison to Baker & McKenzie's Global Tax Practice Group for the Technology Media and Telecom.

Practice Focus

For nearly twenty-five years, Erik has advised 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, manufacturing, retail, payments and fintech, and life sciences.


Representative Legal Matters

  • Advised on restructuring responses to domestic and international changes in tax law, including the OECD Pillar One and Pillar Two initiatives.

  • Prepared comments and comment letters in response to legislative proposals for unilateral measures and DSTs and/or OECD Public Consultations.

  • 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.

  • 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.

  • 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


  • California~United States (2001)


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


  • 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, "Field Guide to Going Global," Baker McKenzie, 2024

Author, "Always to consider: Tax Planning and Corporate Development," Chapter 14, Field Guide to Going Global: Legal Resource for Companies Taking Business Models, Products, and Technology International, Baker McKenzie, March 2024

Co-author, "Cloud Transactions: A Survey of Six Countries in Southeast Asia," Bloomberg Law News, September 13, 2023

Co-author, "Big Data and Tax - Domestic and International Taxation of Data Driven Businesses," US Reporter, 2022 IFA Cahiers, Vol. 106B

Co-author, "Tax Considerations of Remote Work Arrangements Around the World," Bloomberg Tax, Daily Tax Report: International, September 22, 2022

Co-author, "Final FTC Regulations Cause Double Taxation — Burden(s) Falls on Taxpayers," 51 Tax Mgmt. Int'l J. No. 2, February 2022
Part 1: Net Gain and Attribution Requirements
Part 2: Covered Withholding Taxes and Other ‘In Lieu of’ Taxes
Part 3: The Best of the Rest — FTC Timing Rules and Disregarded Payments

Co-author, "Protecting Privilege in the 'Work From Anywhere' Era," Tax Executives Magazine, November-December 2021