James O'Neal

James O’Neal

Principal

Phone: +352 26 27 22 40

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Practice Focus
Tax

James is a Principal on AMMC Law’s Tax team. Recognized by International Tax Review as a key leader, James has been practicing tax in Luxembourg for over 11 years. Prior to joining AMMC Law, James was a Director of the International Tax Team of a Big Four in Luxembourg and began his career in Silicon Valley, California during the “dot.com” boom years.
He regularly advises Fortune 500 companies, start-ups, and private equity firms on many aspects of Luxembourg taxation including IP planning, cross-border financing, mergers & acquisitions, and restructurings.

Admissions
Florida (1999)
Not admitted to practice law in this jurisdiction

Education
LL.M. in Taxation, New York University, Law School, USA (1999)
J.D. with Honors, University of Florida, College of Law, USA (1997)
B.A. University of Florida, USA (1993)

Languages
English, French, Spanish
James is active in keeping Luxembourg an attractive location for global business. He is the Treasurer of the American Chamber of Commerce and is a member of both its Executive and Tax Committees.  He has also served on multiple joint committees on reforming Luxembourg’s IP tax law. James has multiple published articles on Luxembourg tax aspects, and notably he was the chief author of IBFD’s Luxembourg Survey, Corporate Tax Section, from 2005 to 2013. 

James’ transactions and representations include (non-exhaustive):
  • A multi-billion dollar restructuring of a major consumer goods distributor’s global financing and holding structure spanning North America to China with Luxembourg companies as a central hub for the tax efficient cross border internal financing and holding activities.
  • Optimal utilization of billions of dollars in tax losses as a result of a distressed debt restructuring of a major computer manufacturer via Luxembourg SPVs.
  • Luxembourg IP tax planning for a major gaming company’s global business model involving complex service and distribution arrangements with strategic social network partners located from East Asia to Silicon Valley.
  • Multi-million dollar IP tax planning for a major pharmaceutical company’s acquisitions of multiple high valued patents and trademarks from various targets.
  • Restructuring a US software giant’s IP tax planning with a combination of Luxembourg and Puerto Rico SPVs which also included cross border financing and holding activities.
  • Financing the acquisition of multiple real estate projects of a major Canadian real estate developer via Luxembourg SPVs to achieve strategic business objectives and overall structural reductions in tax rate.
  • Acquisition and financing of a Mexican target by a major Canadian automotive parts company via Luxembourg securitization vehicle.
  • Multiple private equity acquisitions and refinancings involving Luxembourg SPVs to both hold and finance the target companies in a variety of industries. 
  • Utilization of Luxembourg SPVs for the financing of a target acquisition by a major software company to achieve substantial tax savings on their global structural tax rate.