Michael is a corporate tax specialist who advises major financial institutions, real estate and retail companies on effective tax structuring. His advice often involves the tax implications of complex UK real estate transactions. Michael regularly assists with Stamp Duty Land Tax (SDLT) and real estate VAT and capital allowances issues, and is also experienced in dealing with property-based securitisations and corporate intra-group asset reorganisations and debt restructurings.
Expertise
- Property-based securitisations
- Off-balance sheet structures
- Intra-group asset reorganisations and liquidations
- Landlord and tenant
- Property development and financing
- Infrastructure and utilities
- Corporation tax
- Real estate VAT
- Stamp Duty Land Tax (SDLT)
Experience
- Advised a Government agency on the multimillion-pound financing of a residential development by major property developers.
- Advised Tesco on real estate structured financing and securitisations and numerous transactions relating to its real estate portfolio (including residential), with a particular focus on VAT, SDLT, capital allowances, capital gains and other real estate tax aspects.
- Advised National Grid on disposal (for over £30m) by way of TOGC to a major developer for the residential development of a major site at Southall and on proposed acquisitions of multiple land interests in connection with a major project.
- Advised Thames Water (ongoing) on the tax implications of Thames Tideway Tunnel Project, focussing on VAT and SDLT.
- Acted for a major REIT (with a multibillion-pound real estate portfolio) on several high-value transactions, including, in particular, on VAT and SDLT aspects of a major mixed use development major lease regearing and sale of land for a major government infrastructure project.
- Advised (another) major REIT on its high-value portfolio of lettings and discrete large-scale development with particular emphasis on VAT aspects and SDLT.
- Acted on the £100m+ debt restructuring of a major private property investment group.
- Advised a major client on the direct tax implications of the transition to new accounting standards (FRS 102).
- Acted for a major Canada-based rating agency on numerous RMBSs.
- Acted for a major UK client over a six-year period on an ongoing HMRC SDLT enquiry (up to £50m).
- Acted for major US law firms and a major US multinational investment bank and financial services company bank in connection with taking lettings of office space.
- Acted for a landlord on a highly complex £140m City development in relation to preserving for landlord capital allowances on £90m landlord’s contribution.
- Advised the real estate arm of a substantial private bank in relation to tax implications of major internal asset reorganisation/refinancing (including advice on corporate interest restrictions).
- Advised an offshore company on corporate tax implications of acquisition, holding and potential future disposal of a substantial real estate development in London.
Please note: The experience list above may include examples of work completed prior to joining Keystone Law.
Career
Michael qualified as a solicitor in 1997. Prior to joining Keystone Law in 2019, he worked at the following firms:
- Bryan Cave Leighton Paisner
- Allen & Overy