Hugh has extensive experience acting on the taxation aspects of mergers and acquisitions, including negotiating transaction documents and providing tax structuring advice. He has expertise in the taxation of financing transactions, in particular securitisation structures, debt issuances and cross-border lending. Another core area of Hugh’s practice is advising high net worth individuals on New Zealand tax matters, with a particular focus on the New Zealand tax treatment of overseas trusts and other overseas holding structures.
ASB divestment of Aegis
Acting for ASB on the sale of Aegis, an investment administration and custody business, to MMC, including preparing and negotiating the tax aspects of transaction documents.
Sale and lease back of James Fletcher Drive
Providing tax advice to Toll on the sale and lease back of its James Fletcher Drive freight forwarding facility.
New Zealand Government Vaccine Strategy Task Force
Advised the New Zealand Government Vaccine Strategy Task Force on advance purchase agreements to secure a portfolio of COVID-19 vaccines for New Zealand, Niue, Tokelau and the Cook Islands.
Advising professional trustees, originators and noteholders in relation to the tax aspects of securitisations, including preparing “tax neutrality” opinions and preparing and reviewing the tax aspects of the transaction documents.
Advising lenders and borrowers alike on the New Zealand tax aspects of various types of loan facilities, including syndicated, bilateral and club arrangements and negotiating tax clauses with opposing counsel.
Advising new migrants and non-residents on New Zealand tax residence issues, the application of the transitional resident exemption regime, double tax agreement issues and restructuring of overseas holding structures.