Tax

• Jan 2022 - Present

Director

• Dec 2020 - Jan 2022

Head of Capital Gains Tax - Tax & Regulatory Team, Global Product Management

• Oct 2017 - Jan 2022

Head of Capital Gains Tax, and member of the Tax & Regulatory Team in the Global Product Management, which provides a wide range of tax services and expertise to our global custody clients,

Senior Manager International Tax

• Nov 2016 - Sep 2017

I am an international tax Senior Manager in PwC Ireland's financial services tax practice specialising in both international tax structuring of investment funds, and on Irish and international real estate as asset classes. I have significant practical experience in custody tax and operational issues across a wide range of funds, including in particular CCFs, ETFs, UCITS and AIFMD funds. I also advise on structuring options for investing in real estate, both in Ireland and internationally, for a variety of investor types. Show less

Assistant Vice President

• Apr 2013 - Nov 2016

Member of the Product Tax Europe team, which manages the overall tax service offering for Irish funds and a number of other jurisdictions, including product development, project management, client take on and client relationships. I specialize in custody tax issues (foreign withholding tax and capital gains tax), pooling vehicles and domestic tax matters. I also have overall responsibility for the Irish Custody Tax Team, which manages tax documentation and reclaims across State Street's Irish funds (both opaque and transparent), and provides various client deliverables and tax reporting. I have a strong focus on tax research, monitoring global developments, and devising solutions for our client base. Show less

Tax Officer

• May 2010 - Mar 2013

Tax specialist with State Street: Primary Role: Dealing with custody tax issues arising for Irish investment funds throughout the world, with a focus on withholding taxes on income and capital gains tax liabilities. Also incldues•Researching and monitoring tax developments, and communicating relevant developments internally and externally;•Providing tax risk assessments for funds;•Developing process efficiency solutions for custody tax•Advising on Irish tax issues arising for investment funds•Working with industry groups on tax matters;•Dealing with auditor queries on funds under our administration;•Preparing and delivering tax service presentations to external clients;•Ad hoc tax research•Primary contact point for escalation of custody tax issues. Show less

Tax Lawyer

• Nov 2007 - May 2010

My work involved providing tax planning and solutions both directly to clients, as well as to the various departments of the firm. I also dealt with ad hoc tax queries arising in various departments of the firm, as well as drafting and advising on tax documentation. My role involved significant amounts of research, keeping up to date with all relevant tax legislation and commentary, and ensuring quality output while at all times maintaining the necessary attention to detail. Role included advising on INTERNATIONAL TAX ISSUES  Inward investment for foreign (particularly US) companies;  Ddouble tax treaty issues;  Setting up of group holding companies in Ireland for EMEA region;  Withholding taxes for companies distributing profits and interest out of Ireland;  Exit Charge mitigation PRIVATE M&A TRANSACTIONS  Tax implications of M&A transactions;  Tax due diligence;  Negotiating Tax Deed of Indemnity and Tax Warranties;  Ad hoc tax queries arising during transactions.  Exit strategies for shareholders, including earn-outs etc. CORPORATE TAX ADVICE  Tax implications of various restructurings;  Section 79 and section 80 stamp duty relief applications, and application of CGT reliefs;  Effective us of losses throughout corporate group (multinational);  Business Expansion Scheme (BES) investments from a tax perspective; VALUE ADDED TAX  VAT implications on various transactions;  Place of supply for services. PERSONAL TAX • Exit strategies from companies; • Estate planning structures; • Tax shelter structures utilising capital allowances (Hotels, Nursing Homes, Hospitals). EMPLOYMENT TAX  Tax efficient structures for profit sharing schemes for employees;  Tax issues arising on redundancy payments; STAMP DUTY  Stamp duty treatment of various documents for resident and non-resident companies / individuals;  Stamp duty mitigation structures; Show less