Tax: Experience

MERGERS & ACQUISITIONS CORPORATE


  • Nabriva Therapeutics on the redomiciliation of its Holding Company from Austria to Ireland, by means of an Exchange Offer.
  • Johnson Controls on the spin-out of its automotive business (Adient) into an Irish plc listed on the Irish Stock Exchange.
  • Johnson Controls on its merger with Tyco.
  • Endo International on its acquisition of Auxilium Pharmaceuticals in a cash and stock transaction valued at approximately $2.6bn.
  • Global Indemnity on its re-domestication of the Global Indemnity group from Ireland to the Cayman Islands.
  • Pfizer on its cancelled $160bn merger with Allergan.
  • Endo on its acquisition of Par Pharmaceutical Holdings, Inc for $8.05bn.
  • Endo Health Solutions on its $1.6bn acquisition of Paladin Labs and related corporate inversion into Ireland.
  • Citibank on the crossborder merger of Citibank International and Citibank Europe.
  • XL Group on its $4.2bn acquisition of Catlin Group.
  • Medtronic on its $49bn acquisition of Covidien.
  • Pozen on its acquisition of Tribute Pharmaceuticals.
  • Towers Watson on its merger with Willis Group.
  • Credit Suisse AG on the disposal of Fortis Prime Fund Solutions.
  • AIG on its sale of ILFC to AerCap.
  • Jazz Pharmaceuticals on the reverse takeover of Azur Pharma and corporate inversion of the NASDAQ listed Jazz entity to Ireland.
  • élan on the tax aspects of its sale to Perrigo Company.
  • Telefónica on its €850m sale of O2 Ireland to Three’s Hutchison Whampoa.
  • Jose Cuervo on its acquisition of the Old Bushmills Distillery.
  • Sumitomo Mitsui Banking Corporation on its acquisition of RBS Aerospace.
  • Vidara Therapeutics on the acquisition of Irish listed pharmaceutical company AGI Therapeutics and subsequently on its merger with Horizon Pharma.
  • Fintrax Group on its disposal to the company’s management team and Exponent Private Equity.
  • Aegon on the US$1.4bn sale of Transamerica International Re Ireland, to SCOR.
  • IBM on its acquisition of Curam Software.
  • Permanent TSB on sale of Irish Life to the Irish Minister for Finance.
  • ICON on its acquisition of Firecrest.
  • Citi on the sale of Citilife Financial to Enstar Group.
  • Wells Fargo on its acquisition of the US loan books of Bank of Ireland, Anglo Irish Bank and Allied Irish Banks.

CAPITAL MARKETS


  • Permanent TSB on the first issuance of Additional Tier 1 securities to facilitate its repurchase of contingent capital notes held by the Irish Government.
  • Irish Property Unit Trust, a €1bn euro Irish property fund, on the tax aspects of its conversion to a regulated fund.
  • Jazz Pharmaceuticals on its US$575m debt fund raising and US$1bn convertible loan note offerings.
  • Ryanair on the establishment and listing on the Main Securities Market of the Irish Stock Exchange of Ryanair's €3bn euro medium term note programme.
  • Bank of America, Merrill Lynch and Deutsche Bank, London Branch in connection with the €500m structured financing of a portfolio of credit card receivables, originated by AIB.
  • Hibernia REIT on the tax aspects of its €385m IPO and listing on the official lists of Dublin and London.
  • Intermediate Capital Group/St Paul's CLO IV on St Paul's €435m CLO issuance managed by Intermediate Capital Group.
  • Prothena Corporation in relation to its US$130m primary and secondary capital raising.
  • Irish Continental Group on the return of capital to shareholders by way of tender offer.
  • Banco Santander SA on a securitisation of auto loans and leases of Santander Consumer Bank AS.
  • Cableuropa SAU in connection with a €300m high-yield bond issue through Nara Cable Funding.