James Somerville, Partner - A&L Goodbody

James Somerville


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 and cross border financings, mergers and acquisitions, inward investment, group re-organisations and property acquisition and holding structures.

Experience

Deals on which James has advised include the following:

  • Global Indemnity plc on its re-domestication of the Global Indemnity group from an entity incorporated in Ireland to an entity incorporated in the Cayman Islands.
  • Permanent TSB in relation to taxation aspects of its 2015 fund raising through its additional Tier 1 Capital and equity issuance.
  • Irish Property Unit Trust now IPUT plc in relation to the taxation aspects of its conversion from a unit trust to a regulated corporate investment fund and its expansion of its investor universe as well as in relation to a number of significant property acquisitions.
  • Endo International plc on its acquisition of  Auxilium Pharmaceuticals in a cash and stock transaction valued at approximately $2.6bn.
  • Carlyle, KKR, Oaktree Capital 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 a NOK 10bn auto loan securitisation the first ever Norwegian securitisation, and several subsequent scandinavian securitisations.
  • Bloomberg LP on its acquisition of Irish software company Polarlake for an undisclosed sum.
  • Deutsche Bank in relation to its financing of and participation in the purchase of the UK property loan book of Bank of Ireland, the largest UK portfolio loan sale in 2011.
  • 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 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 its reorganisation to implement a new Irish resident holding company and tax aspects of certain financing transactions.

Market Recommendations

  • "Concise, getting to the heart of matters quickly and helping us to see our options clearly. He is also very good at breaking down the issues." (Chambers Europe 2016)
  • "Highly respected practitioner." (Chambers Global 2015)
  • "Tax savvy, particularly related to international tax regimes and is noted for his ability to deal with tax issues in a practical way." (Chambers Global 2014)
  • “Highly adaptable tax lawyer who brings a creative approach to complex transactions." (Chambers Global 2012)

Education

  • LLB, Trinity College Dublin, 1992
  • Solicitor, Law Society of Ireland, 1996
  • Solicitor, Law Society of England and Wales

Professional activities

James currently sits on Main TALC the main forum for liaison between tax practitioners in private practices and the Irish tax authority, the Revenue Commissioners. James is the former Chairman of both the Foreign Lawyers Forum of the Taxation Section of the American Bar Association and the current Chairman of the Taxation Committee of the Irish Law Society. He contributes regularly to legal and tax publications as well as speaking frequently at conferences and seminars on matters of Irish and international taxation. James is also an Associate of the Irish Taxation Institute.

James Somerville

T: +353 1 649 2340

Email: James Somerville

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a highly respected practitioner

(Chambers Global 2015)