James Somerville is a Partner in the Tax Department. He advises on all aspects of taxation law but with particular emphasis on financial services and property related tax, including structured finance transactions, capital market issues, investment funds, mergers and acquisitions, group re-organisations and property acquisition and holding structures.
Deals on which James has advised include the following:
- Goldman Sachs on numerous structured finance, CLO, CDO, CMBS and repackaging platforms.
- Carlyle, Apollo, KKR and Fortress Investments on fund and debt platforms; and tax efficient structures for holding international property portfolios.
- Morgan Stanley in relation to the tax aspects of the issuance of shares to the Irish National Pension Reserve Fund Commission and the related de-listing of Allied Irish Banks from the main market of the Irish Stock Exchange and move to the Enterprise Securities Market.
- UBS and Deutsche Bank on the two Bank of Ireland liability management exercises in 2010 involving exchange offers to subordinated note holders for new ELG guaranteed notes.
- Banco Santander in connection with the NOK 10bn auto loan securitisation the first ever Norwegian securitisation.
- Cableuropa SAU, one of the largest Spanish fixed line/broadband providers in connection with the issue of €300m high yield bonds through Nara Cable Funding Limited.
- Abu Dhabi based sovereign wealth fund Waha Capital on its acquisition of a 20% stake in Aercap and the restructuring of its existing 50% joint venture.
- Genzyme on certain Irish tax aspects of its $20bn acquisition by Sanofi Aventis.
- Aegon on Irish tax aspects of the $1.4bn sale of its reinsurance business Transamerica International Re Ireland to SCOR.
- WPP Group plc on the reorganisation to implement a new Irish resident holding company.
- Pfizer on the disposal of its Loughbeg plant to Hovione in particular on stamp duty issues.
- Santander Financial Products plc (SFP) and Banco Santander, S.A. (Santander) in respect of the establishment of a €2.5 bn retail certificate note programme by SFP which is guaranteed by Santander.
- Hellman & Friedman in its acquisition of Web Reservations International owner of Hostelworld.com for an undisclosed sum.
He is recommended in a number of leading international directories including: World Tax 2011; Chambers Global 2011; Chambers Europe 2011; PLC Which Lawyer? 2011, Who’s Who Legal 2011, Best Lawyers 2011 and Guide to the World’s Leading Tax Advisers 2011. "He is a popular client choice because he understands the requirements of his clients and provides sensible, focused, accurate advice” (Chambers Global 2010).
James is Vice Chairman of both the Taxation Committee of the Irish Law Society and the Foreign Lawyers Forum of the Taxation Section of the American Bar Association. He contributes regularly to legal and tax publications as well as speaking frequently at conferences and seminars on matters of Irish and international taxation.
He qualified as a solicitor both in Ireland and England and Wales and is an Associate of the Irish Taxation Institute. He has a Law degree from Trinity College, Dublin.