Advised in relation to a $650m subordinated hybrid public issue to raised funds for ongoing capital management initiatives of an Australian energy business, including advising on legal documentation and dealing with the Australian Taxation Office in respect of obtaining a private binding ruling.
Advising a gas and electricity business on tax consolidation issues associated with a significant consolidation event, including the allocation to privatised assets and the recognition of losses.
Providing support in a major tax controversy, including analysis in relation to capital allowances, the treatment of certain asset disposals having regard to tax consolidation outcomes, and assisting in dealing with the ATO's information requests and the preparation of amended assessments and objections.
Performing a review of CFC attribution calculations.
Tax specialisation in FATCA, AEOI / CRS and Qualified Intermediary regimes, including advising financial institutions on technical aspects of the implementation of these regimes, including in relation to classifications, documentation, due diligence, reporting, withholding, certification and reviews/audits, as relevant.
Advised a holding company of worldwide energy businesses, based in Hong Kong and its Australian operations, on tax structuring advice regarding a significant corporate and financing restructure involving international debt refinancing and foreign and Australian liquidations, and considering cross-border tax and transfer pricing issues.
Advised a consortium on technical structuring issues (including tax consolidation) associated with making a successful multi-billion dollar joint bid for an Australian energy business.