Amelia O'Beirne is a Tax Partner in the firm's Dublin office. She has extensive experience advising domestic and international clients on both transactional matters, including public and private company mergers and acquisitions, debt and equity capital markets transactions and complex cross border financing transactions, and on contentious matters such as tax authority enquiries and international tax disputes.
Amelia regularly assists clients in resolving transfer pricing and other tax treaty related issues through competent authority processes and the negotiation of advance pricing agreements. She has extensive experience advising US multinationals on cross border tax matters, having spent three years in the firm’s New York office.
Amelia represents a broad spectrum of clients in various industry sectors, including life sciences, technology, financial services and aircraft leasing.
Areas of Expertise
- US listed company in requesting Irish Competent Authority (MAP) assistance under the Ireland/US DTT in respect of a significant IRS transfer pricing assessment.
- Nabriva Therapeutics on its acquisition of Zavante Therapeutics, the redomicile of Nabriva from Austria to Ireland, its listing on NASDAQ and subsequent equity fundraisings.
- Irish listed group in successfully negotiating with Irish Revenue to secure a tax refund which was under appeal to the Tax Appeals Commission.
- Osmotica Pharmaceuticals on its migration from Luxembourg and IPO on NASDAQ.
- Iterum Therapeutics plc on its IPO on NASDAQ.
- Canadian asset management firm in respect of a transfer pricing adjustment imposed by the CRA and corresponding adjustment pursuant to the Ireland/Canada DTT
- Johnson Controls Inc. on its $20bn merger with Tyco plc and the subsequent spin-off of its automotive business to a separate NYSE listed entity (Adient plc).
- Multiple US multinationals in relation to negotiations for bilateral advance pricing agreements with Irish Revenue.
- Pfizer on its proposed $160bn merger with Allergan.
- Towers Watson on its merger with Willis Group.
- Endo International on its agreement to acquire Par Pharmaceuticals Holdings, in a cash and stock transaction valued at approximately $8bn.
- Medtronic on its $49bn acquisition of Covidien.
Amelia is a member of the American Bar Association and International Bar Association and a frequent speaker on international tax topics at conferences and seminars. Amelia previously served as National Reporter for Ireland to the International Bar Association Taxes Committee.
- Associate of the Irish Taxation Institute
- Solicitor, England & Wales
- Solicitor, Ireland
- LLB, NUI Galway
- B Corporate Law, NUI Galway