• Advising a UK-based property asset manager on the establishment of a GBP250 million open-end real estate fund, structured as a Jersey property unit trust, which invests in government-backed real estate in the UK. We also advised on the application of the new capital gains tax rules for non-residents to the JPUT, and on the drafting and negotiation of transaction documents on acquisitions of properties, including office, industrial, and senior living.
  • Advising Leidos Holdings on its acquisition from L3 Harris of its security detection and automation business for USD1 billion, including advice on the tax consequences of a substantial pre-sale reorganisation across 12 jurisdictions.
  • Advising a number of W&I insurers in relation to the tax aspects of warranty and indemnity insurance and tax risk insurance policies.
  • Advising a French asset manager on the tax consequences for UK individual and corporate investors of investing in a Luxembourg fund, including consideration of the application of the offshore funds rules to the proposed structure, and preparing the UK tax section of the private placement memorandum.
  • Advising Hain Celestial Group on the sale of its Tilda Rice business to Ebro Foods for USD342 million.
  • Advising a German business on the UK insurance premium tax consequences of standalone and group insurance contracts, including advice regarding the location of the risk where the named policyholder and policy beneficiaries differ, and corresponding with the tax authority to agree the position.