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Taxation

Although the tax practice was only established in late 2004, it has already established itself as one of the leading financial services tax practices in the country. Our Tax team is multi-disciplinary and is comprised of a combination of tax, legal and accounting professionals providing a comprehensive range of tax services to domestic and international clients across all areas of international financial services in particular in the areas of Asset Management & Investment Funds, Securitisation and Structured Finance, Private Equity, Capital Markets, Banking, Treasury and Reinsurance working closely with the firm's other practice groups. 

Cross border transactions are conducted in conjunction with tax counsel in other jurisdictions based on extensive relationships built up over many years .

Set out below are just some of our recent deals:

  • acting as lead tax counsel for Lone Star as the originator in the €1.34 billion German non-performing loan securitisation, Bluebonnet plc, which was the largest European NPL transaction at that stage and which won the ISR Deal of the Year 2006 Award. 
  • acting as Irish tax counsel for Citigroup’s Corporate and Investment Banking Asset Backed Securities Issuance programme, the CABS programme, which was nominated for the IFLR Asian Securitisation Deal of the Year 2006 Award and was the world’s first rated securitisation of trade loans and was issued by an Irish SPV, ABS Global Finance plc and was arranged and lead managed by Citigroup Global Market.
  • acting as Irish tax counsel in connection with the Ivory CDO transaction, a €200 million securitisation of structured finance assets including primarily residential and commercial mortgage backed securities, and for CFO Premium, a €200 million market value collateralised fund obligation, both transactions arranged by SGAM Finance and managed by SGAM Alternative Investments SA.
  • acting for JP Morgan Securities as Irish tax advisor in connection with a $220 million participating note issuance by a newly authorised Irish special purpose reinsurance vehicle as part of a securitisation of catastrophe and aviation risk for the world’s leading global reinsurer.
  • acting for the vendors of Moyglare Holdings Limited in their sale of the Company to Doyle Group.
  • acting for the vendors of Masterclean Limited and the vendors of Rescon IT in their disposal to Harvey Nash Group plc.
  • in addition, the tax department in conjunction with the corporate and commercial department advised a global risk management group on the Irish tax aspects of a €350 million re-organisation.
  • acting for FBD Group plc on their recent return of capital to shareholders.
  • acted as Irish tax counsel on a number of European real estate development structures (e.g. France, Spain and in particular Germany).

 

The Tax team has also acted as Irish tax counsel for a number of international private equity promoters. For example in 2008 the group has acted as Irish legal and tax counsel in the financing of the US$2.4 billion acquisition by Japan’s largest buyout fund of a Japanese regional bank.  The transaction was Japan’s biggest bank takeover in recent years. 

Finally, the team has advised on numerous investment fund establishments and a multitude of onshore/offshore fund reconstructions and amalgamations as well as restructuring advice in relation to an array of fund service providers.

Recent endorsements include:

  • “The increasingly impressive tax practice at Dillon Eustace garnered some quality mandates in 2007 and of these, advising Lone Star on the tax aspects of the €1.3bn German NPL securitisation, Bluebonnet, stands out.” The Legal 500' 2007 
  • The “fantastic” David Lawless (head of tax) of Dillon Eustace is “helpful and responsive and very clued up with what is happening with the regulators,” say clients. He oversees an expanding tax practice of “responsive and competent” advisers, and provides support to the firm’s financial services and corporate clients. He also supplies standalone tax advice, primarily on structured finance, securitisation and establishing Irish investment vehicles. Chambers Global 2006 

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