With a market-leading tax practice and offices in three major North American centres plus Paris, Davies is the tax adviser of choice on a full range of cross-border and international transactions, including M&A, financings, joint ventures, reorganizations and spin-offs.
The following list is a small sample of our recent international tax work:
- Alimentation Couche-Tard’s acquisition of The Circle K Corporation from ConocoPhillips Company, and financing of the acquisition by a combination of the issuance of subscription receipts on a private placement basis ($223.6 million), the issuance of senior subordinated notes on a U.S. SEC Rule 144A private placement basis (US$350 million) and senior credit facilities (US$620 million);
- Purchase by Amcor Limited of Australia from Schmalbach-Lubeca AG of Germany of its international plastic containers (PET) and closures businesses for Euro 1.725 billion (US$1.56 billion), involving 58 subsidiaries located in 26 countries;
- Acquisition by Barrick Gold Coproration of a substantial minority position in Highland Gold Mining Ltd., a UK listed company with operations throughout Russia;
- Acquisition by SITQ Immobilier of the 1515 Broadway (VIACOM) building in New York City with SL Green Realty Corp. (approximate value US$500 million);
- Acquisition by Celestica Inc. from NEC Corporation of two advanced manufacturing facilities in Japan, which are engaged in the development and manufacturing of advanced optical transmission systems and five-year outsourcing agreement anticipated to generate revenue of up to US$2.5 billion during its five-year term.