Barney Cumberland

Arena Investors, LP (and related entities)

Tax and structuring advice on new and continuing New Zealand investments worth in excess of $400 million and on a proposed expansion/restructuring of its New Zealand lending business.

Pallas Capital Pty Limited

Tax and structuring advice on expansion of lending operations into the New Zealand market.

NZ Rugby 

Transactional tax advice in relation to Project Future, the formation of a commercialisation joint venture with American private equity firm Silver Lake.

Adamantem Capital Management Pty Ltd and Heritage Lifecare Ltd

Principal legal tax advisor on Heritage’s $280 million care home property sale and leaseback transaction with Centuria Capital Group.

DoorDash, Inc.

Advised Doordash, a US multinational that operates an online food ordering and food delivery platform, on tax aspects of its entry into the New Zealand market.

Lodestone Energy Ltd

Tax advice in relation to various aspects of its prospective development of a network of solar generation farms throughout New Zealand.

Multi-national enterprises

Advised numerous large multi-national enterprises on the impact on their NZ subsidiaries of BEPS related changes to NZ income tax rules and NZ’s remote services and distantly taxable goods GST rules.

High net worth individuals and families

Advised numerous high net worth individuals and families on tax, trust and asset protection matters, including with respect to business succession arrangements, the impact of the Trusts Act 2019 and international and domestic disclosure matters.

Public Sector Advisory

Auckland City Council, Auckland Transition Agency, and the Auckland Council group 

Advised on multiple projects, including tax aspects of the Auckland Council reorganisation and post-reorganisation structuring and transactional advice, establishment of the Council’s charitable trust council-controlled organisation (CCO) Regional Facilities Auckland, establishment of the Council’s urban development CCO (Panuku Development Auckland), the 2020 amalgamation of ATEED and Regional Facilities Auckland Ltd into Auckland Unlimited, America’s Cup funding issues and various income tax, GST and charity/not-for-profit matters for the Council group.

City Rail Link Ltd  

Advised on its income tax and GST position, including liaising with Treasury and Inland Revenue, and on the transfer of assets from Auckland Council.

Tamaki Redevelopment Company Ltd/Tamaki Regeneration Ltd/Tamaki Housing Association LP

Principal tax advisor on structuring and tax issues since their establishment to undertake urban regeneration in part of Auckland.

Not-for-Profit Sector Advisory

Tait Ltd/Tait International Ltd/Tait Foundation/Tait Contel Charitable Trust

Advised on a significant internal restructuring and the subsequent part sale of the Tait electronics business to JVC Kenwood Corporation.

Skills Inc. 

Providing ongoing advice to Skills, New Zealand’s largest industry training organisation, on various acquisitions and its transitional arrangements under the Government’s ROVE reforms.

Waikato-Tainui  

Advised Waikato-Tainui on numerous ventures undertaken within the auspices of its charitable trust ownership structure.

Disputes and Litigation

United States Department of Justice

Expert witness in relation to New Zealand aspects of a significant international tax case between the US Government and a large US multi-national.

Structured finance litigation

Advocate for a leading NZ bank in its NZ$960 million structured finance tax dispute - Westpac Banking Corporation v Commissioner of Inland Revenue.

Convertible note tax disputes

Represented taxpayers in tax avoidance disputes with the NZ Revenue over financing transactions involving the use of optional or mandatory convertible notes.