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SJ Berwin's tax department comprises 18 partners and 28 other fee earners under department leader Heather Corben. The firm is distinguished from competitors by the extent of work undertaken in private equity, M&A and real estate funds. The team's expertise ... [more]

SJ Berwin's tax department comprises 18 partners and 28 other fee earners under department leader Heather Corben. The firm is distinguished from competitors by the extent of work undertaken in private equity, M&A and real estate funds. The team's expertise in all three of these areas was important to its work for Pantheon Ventures in the sale of the business to AMG. Pantheon had to be restructured into a limited liability partnership before the sale and the resulting tax issues coordinated across New York, Hong Kong and London. Corben led the team that advised British Land on its joint venture with Oxford Properties, a Canadian pension and investment fund, to begin the $777 million development of its Leadenhall building. Using the right structure for the joint venture was essential to ensure the different characteristics of Oxford Properties and British Land were accommodated. As both debt and equity funding was used to facilitate the joint venture, the particular consequences arising in respect of the real estate investment trust (REIT) rules as well as SDLT and VAT had to be considered. New partner Giles Bavister oversaw Crown Estate's appointment as manager of Norges Bank Investment Management's (NBIM) $725m million 150 year lease of Regent Street. The structure needed to accommodate various commercial objectives of both parties and due to the public profile of Crown Estates had to be capable of withstanding close scrutiny. This involved a number of SPVs being interposed in the chain of ownership and deployment of partnerships within the structure to preserve efficiency and prevent tax leakage. Consultation with HMRC to obtain clearance for the treatment of SDLT in the transaction was also highlighted by Corben as an important feature. The firm notes that while it has seen a rise in instructions over the year, much of the new work relates to cross border restructuring and advisory matters rather than the transactional work which was the former mainstay of the department.