Larry specialises in corporate and international income tax. He has been recognised as one of the 10 star performers of the Australian legal profession (and the only one in tax) by Chambers Asia Pacific 2012. Larry was described by one client as head and shoulders above anyone else in the Australian tax market...[He is] very commercial, analytical, quick on his feet, and very good in round-table discussions with the tax office.
Larry advises on the taxation aspects of mergers and acquisitions, restructures and reorganisations of corporate groups and trusts, as well as project, asset and other corporate financings. He also advises on the development of new financial products, international tax planning, withholding taxes, income tax treaty matters, and tax audits and investigations.
Larry has acted on some of Australia's largest and most innovative transactions, including the establishment of dual listed company structures for Rio Tinto, BHP Billiton and Brambles-GKN; the proposed dual listed company structure for Origin Energy Limited and Contact Energy Limited; the unification of the Brambles structure; and the Wesfarmers acquisition of Coles.
He has also advised Westpac on its off-market share buy-back tenders, its hybrid tier 1 capital issues (including its innovative New Zealand tracking share issue), its sale of AGC, its acquisition of the BT Financial Group, its partial float of BT Investment Management and its tax consolidation of St.George Bank Limited (which Westpac announced in October 2010 and March 2011 had resulted in a A$1.8 billion reduction in its tax expense). His work on corporate restructures has included approaching Government to make facilitating amendments to the Commonwealth Income Tax Assessment Act.
Larry is admitted to practice in New South Wales, Victoria, Western Australia, New York and the United States Tax Court. He is a Fellow of The Taxation Institute and a member of the Law Council of Australia's Taxation Committee. He is the author and co-author of numerous papers and articles on Australian and international taxation law and has consulted with the Treasury and Australian Taxation Office in relation to Business Tax Reform, including scrip for scrip roll-over, demerger relief, the debt/equity classification rules and the general anti-avoidance rules. He is a member of the Commonwealth Board of Taxation's external Advisory Panel and he represents the Law Council of Australia on the Finance and Investment Sub-committee of the Commissioner of Taxation's National Tax Liaison Group.
Areas of Expertise
- Tax, specialising in:
Dual Listed Corporations
Mergers & Acquisitions
- Private Equity
- Focus - 17 October 2012