Stuart Broadfoot

Acted on a number of mandates for clients (both startup and established entities) on US "flip-ups"/redomicile involving the "top-hatting" of Australian groups with a US holding company to enable better access to capital funding, coordinating across Australia, the United States and other relevant jurisdictions to implement in a tax-effective manner for both shareholders and employee share option plan participants.

Acted as lead Australian tax counsel on establishment of an Australian feeder fund for global private equity fund manager to enable investment by Australian superannuation funds into a significant private equity co-investment based in the United States.

Acted for a US headquartered, NYSE-listed global conglomerate in relation to tax aspects of acquisition of Australian-based software firm.

Acted for the directors of an Australian company that received significant director penalty notices assessing them to liability to unpaid historical superannuation contributions. Negotiated with the Australian Taxation Office to a settlement to relieve the directors of liability.

Advised a significant international pension fund on the range of tax issues associated with the making and funding of various inward private equity investments into Australia. This includes its continued investment into, funding of, and subsequent partial sell down of its interest to a JV partner in one of Australia’s largest transport operators and the associated sale and leaseback of a property portfolio.

Acted as lead solicitor in successful tax litigation for a major Australian rail transport company, obtaining declaratory relief against the Commissioner of Taxation in relation to the tax characterisation of a AU$4.3 billion capital contribution made during its privatisation.

Advised two significant global private equity investment funds on cross-border and Australian tax issues arising from divestment of interests in an Australian headquartered Asian cloud infrastructure business.

Advised a global infrastructure fund manager on tax issues relating to an existing global infrastructure fund, including the launch of a new fund vehicle, structuring of acquisition of major investments by the fund, implementation of a tax governance framework, and preparing tax disclosure summary in investment materials.

Advised several issuers on the issue of publicly listed convertible/exchangeable debt instruments, including advising on interest withholding tax exemptions under section 128F and preparing tax disclosure statements.

Acted for a global beverage firm on tax aspects of sale of part of its Australian business lines, including negotiating transaction documents, and advising on potential sale tax issues.

Advised a major Australian superannuation fund in relation to the tax issues associated with private equity investments into offshore funds in a number of jurisdictions.

Advised a global fund manager in relation to Australian tax implications of changes to cross-border master fund.

Advised a major international oil company on tax aspects of significant oil-related inward investment into East Africa, including negotiating tax aspects of key project agreements with East African governments and advising on investment structure for it and its joint venture partners.

Advised a significant US-based global insurance company on cross-border investments into a property financing business in the UK.

Advised international banks on a range of significant cross-border finance transactions.