Acknowledged internationally as an expert in stamp taxes and related areas of contract, property and regulatory law, Michael has been advising the Corporate, Financial Services and Real Estate Sectors for more than 25 years. He has been involved in 18 stamp tax appeals in the UK and overseas, predominantly as Counsel, but also as a technical consultant and expert witness.
From a client's perspective:
"I have had many interactions with Counsel over the years and rarely have I experienced the level of engagement and understanding that you demonstrated."
Direct access: Michael may be engaged directly through tax or legal professionals in-house.
Michael’s practice includes:
Real Estate -
Advice on transactions and transitional provisions, including risk assessments in relation to the SDLT anti-avoidance provisions such as section 75A FA 2003 and the general anti-abuse rule in section 207 FA 2013.
Asset Management -
SDRT on contributions to, distributions from and transmission into and between equity fund vehicles, including trust, contractual, corporate and exchange traded funds established in Europe, North America and APAC.
Investment Banking and Capital Markets -
SDRT compliance and risk management, pre and post transaction correspondence with HMRC, issues of accountability and agency, the reliefs for intermediaries, stock lending and collateral, flows into and between higher rate systems and the chargeability or otherwise of depositary interests and structured products.
Mergers & Acquisitions -
Transaction tax advice and structuring for IPOs and national, and international, mergers & acquisitions, including applications for pre transaction clearances from HMRC.
From time to time, Michael has been engaged as an expert witness by successful litigants in relation to what constitutes the avoidance of SDLT and the operation of SDRT in complex international M&A. He was the author and editor of Sergeant and Sims on Stamp Taxes from 1994 to 2007, having re-written the book as a loose-leaf service in 2001, and remains a Consultant Editor for this work. He is a member of the Lexis PSL Tax Consulting Editorial Board and regularly assists and represents various industry and professional bodies, including the Law Society of England & Wales, and has appeared as a technical expert in political debate on the BBC.
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