Experience

Eleanor has been practicing since 1992 and specialises in taxation law. She led the expansion of our firm’s Finance Tax practice since 2001. She has particular expertise in international tax structuring through Ireland. She advises on the taxation of capital markets products and on the establishment in Ireland of investment funds and other tax-efficient investment products. Familiar assets classes include real estate, renewables, commodities and an array of financial products. She has expertise and experience in contentious and non-contentious tax dispute resolution in her sectors of expertise.

Key highlights include advising:

  • Allied Irish Banks, p.l.c. on its June 2017 IPO and admission to the official lists of the Irish and London Stock Exchanges
  • Greencoat Renewables DAC, an international renewables fund, in connection with its tax structure, in particular achieving tax efficient warehouse funding
  • Magnetar Solar Australia DAC, an international solar fund, in connection with its tax structure and, working with Australian counsel to ensure the tax efficient acquisition, holding and disposal of Australian solar assets
  • a number of loan origination, acquisition and funding platforms on optimal tax structures considering the new “specified mortgage business” rules in S110
  • a major global financial services business in connection with their case at the Tax Appeals Commission
  • Deutsche Bank - London branch in connection with the Irish tax aspects of the acquisition, holding and disposal or workout of various portfolios of non-performing commercial and residential property loans
  • DBRS on Irish tax matters relevant to the rating by them of various debt issuances by various Irish Issuers
  • a number of aviation finance platforms on optimal tax structures considering Irish and cross-border tax issues
  • a number of real estate funds on optimal tax structures in view of the new Irish Real Estate Fund (IREF) rules
  • on the potential impact of the Multilateral-instrument for BEPS tax treaty measures, the Anti-Tax Avoidance Directive and the BEPS package generally on Irish structures and transactions involving Ireland