Renuka Somers

Renuka assists private clients, corporate groups, and their advisers resolve complex tax and structuring issues.

Renuka specialises in Australian Federal taxes, M&A, trusts, US Federal taxes, Australian and US cross-border structuring, and estate planning.

She is regularly published in the Taxation in Australia and Tax Specialist journals on tax, trusts and cross-border issues, and has also presented on these topics for The Tax Institute of Australia and the Leo Cussen Institute.


Renuka’s experience includes advising:

  • US-Australian taxes [Industries: Tech, hospitality, fashion, retail, real estate, celebrities, private wealth]:
    • Sale of stakeholders interests in US entities;
    • US taxes and cross-border structuring;
    • Tax-effective cross-border estate planning and divorce settlements;
    • IRS reporting disclosure requirements; and
    • Australian trusts and non-resident beneficiary issues;
  • Tax effective Mergers & Acquisitions [Industries: Tech, finance, hospitality, fashion]:
    • stock market pre-listing tax and compliances reviews;
    • restructuring of business groups spanning multiple jurisdictions; and
    • on tax effective sales of private company interests both domestically, and internationally, including advising the vendor of a privately held group on the income tax and corporate compliance issues associated with the divestment of a $0.5 billion interest to an international investor;
  • Ultra-high net worth clients, on:
    • succession and estate planning;
    • divesting individual businesses to specific family members / “blood line” groups, including Family Agreements and Family Constitutions, and structuring inheritances; and
    • Australian Taxation Office risk reviews;
  • Tax consolidated groups:
    • formation, joining, ACA, tax losses (transfer, utilisation, continuity of ownership test, same business test), available fractions, exits, tax sharing and funding agreements.

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