Income & Capital Gains Tax
Experience
Our advice adds real value to our clients' businesses, as the following examples demonstrate.
Our advice adds real value to our clients' businesses, as the following examples demonstrate.
- We advised InterGen on structuring its sponsor investment in the Millmerran Power Project, a 840 MW coal mine power station at Millmerran, Queensland. The project was voted the world's largest project-financed merchant power plant, winning the 1999 Project Finance International Asia Pacific Power Deal of the Year.
- We advised Pasminco and MIM on structured bond issues by Special Purpose Vehicles backed by commodity (silver) forward sales. These transactions provided access to long-term US debt capital markets without debt classification for balance sheet or bank covenant purposes. The industry journal AsiaLaw Profiles 2001 described the Pasminco transaction as 'extremely noteworthy' and noted that 'the deal generated favourable media and broker comment as well as substantial interest from players in the resource industry'. Our role included structuring for Australian withholding tax exemption and maintenance of producer GST-free status, and to achieve tax neutrality for the Special Purpose Vehicles.
- We advised Grand Hotel Group on its scrip-for-scrip merger with Australian Tourism Group, its $50 million public offer of converting preference securities to fund the acquisition of the Hyatt Regency Adelaide, and its acquisitions of the Grand Hyatt Melbourne, Hyatt Canberra and Hyatt Regency Perth to create the second biggest owner of hotel rooms in Australia.
- We advised Smorgon Steel Group Ltd on its $800 million joint public takeover offer (with OneSteel Ltd) for Email Ltd, which was originally a scrip bid including an innovative spin off of Email's whitegoods division to Email shareholders (later restructured as a sale to Electrolux AB). Our role included ensuring shareholder access to the new scrip-for-scrip CGT relief, and negotiating an agreed position with the Australian Taxation Office on the application of the new s.45B dividend substitution provisions.
- We advised Major Holdings Pty Ltd generally on the impact of the proposed tax reforms on their structure and the way they do business.
- We advised Santos Apache joint venture in relation to stamp duty-effective termination and income tax implications of dissolving the joint venture.
- We advised Anglogold group on the ownership structure for its Australian investments.
- We advised Billiton on the ownership structure for its Australian investments.
- We advised Tourism Council of Australia on behalf of the Australian Stock Exchange listed stapled groups in negotiations with government to secure the withdrawal of the Collective Investment Vehicle regime proposed by the Ralph Review of Business Taxation.
- We implemented employee share and option plans for many leading companies in Australia, including ANZ Banking Group, AXA, Coles Myer, Lend Lease, Mayne Group, Ansell and Shell.
- We successfully represented Australasian Feed Pty Ltd in a tax dispute regarding entitlement to deductions for carry forward losses, in the Administrative Appeals Tribunal and subsequently on appeal by the Commissioner in the Federal Court.
- We have acted in numerous complex litigation matters in recent years involving United Energy Ltd, Transurban, Coles Myer, Peters and Browns Foods Limited, Victoria Co Limited and numerous individual taxpayers.