Acting (together with other advisors) for a syndicate of banks in respect of a significant leasing airline group which needed to be restructured – significant tax due diligence undertaken, restructuring advice and implementation of tax plan.
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Taxation
Our multidisciplinary team of leading tax, legal and accounting professionals provides a full range of tax consultancy services across all tax heads for national and international clients
Led by highly experienced Tax partners recognised for their national and international expertise, our Tax team works with multinational and domestic corporations, financial institutions, investment funds and start-ups.
We provide an integrated and comprehensive service, working closely with our colleagues in other practice areas to deliver innovative solutions. The Tax team is a close-knit team who work closely with their clients and pride themselves on their responsiveness and their can-do attitude to solving complex tax problems.
We provide a comprehensive range of tax services to domestic and international clients across all areas of international financial services, including asset management and investment funds; securitisation and structured finance; distressed asset investing/bank deleveraging; corporate banking and real estate finance; corporate tax; real estate development; aviation and asset finance; private equity; reorganisations; corporate migrations; corporate investment into Ireland; international tax planning; mergers and acquisitions; double tax treaties; tax dispute resolution; stamp duty and VAT; tax reporting obligations (including FATCA and CRS); and tax compliance obligations.
Members of our tax team are active in leading professional and business associations and interest groups, including the UK Alternative Investment Management Association (AIMA), Irish Debt Securities Association (IDSA), Irish Funds (IF) – the Dillon Eustace tax team is represented on three IF sub-committees, Law Society of Ireland; Taxes Administration Liaison Committee (TALC) for Direct Taxes and TALC for Indirect Taxes. We have actively participated in consultation processes with Revenue and the Department of Finance which has led to tax changes in Ireland and clients can rest assured we are up to date with all major tax developments.
Relevant Experience
Acting for many US loan origination funds in obtaining treaty benefits under the Ireland/US treaty and in particular advising on the tax transparency of various master funds under Irish tax rules.
Advising a multi-billion-dollar Irish investment fund platform (for family office funds) on the implementation of a tax plan to minimise the effects of the interest limitation and the anti-hybrid rules.
Acting for a number of large private equity entities on real estate transactions (both residential and commercial), including advising on the related tax structuring options (including regulated and unregulated structures).
Acting for several real estate investment structures in raising finance in a tax efficient manner and in developing tax efficient exit structures (including advising on converting regulated property structures into unregulated investment structures and vice versa).
Acting for numerous asset managers on the establishment of both regulated and unregulated Irish investment structures for investment in a wide variety of asset classes.
Acting for a US 1940 Act Fund on restructuring its Irish subsidiary used to invest in US life settlements to minimise the effects of new interest limitation rules.
Acting for many sellers and purchasers in company share sales and advising on tax warranties and indemnities.
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Key Contacts
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We have expertise across a range of industries with with offices in Dublin, Cayman Islands, New York and Tokyo
