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Sam Dames

Partner

CMS Cameron McKenna Nabarro Olswang LLP
Cannon Place
78 Cannon Street
London
EC4N 6AF
United Kingdom
Languages English

Sam Dames is a partner specialising in Tax. Sam has been with the firm since 1996 and her practice primarily involves advising individual, corporate and institutional clients on a wide range of contentious and non-contentious tax issues.

Sam advises both corporate and individual clients in relation to tax dispute prevention, management and resolution. Experience ranges from dealing with HMRC enquiries and tax appeals to advising entities in relation to risk assessments for the purposes of the Criminal Finances Act 2017.

Sam advises family office clients and (both resident and non-resident) high net worth individuals on all aspects of their tax affairs, including optimising their tax position in relation to their homes, businesses and investments.

In addition, Sam advises on a wide variety of corporate transactions, from the innovation required in order to implement structured finance transactions to the skills needed to marshal due diligence exercises across several jurisdictions on global acquisitions, with a particular focus on the Financial Services, Hotels & Leisure, Infrastructure & Project Finance, Life Sciences & Healthcare and Technology, Media & Telecommunications sectors.

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Relevant experience

  • BG on a GBP 562m deal for the disposal of its CATS pipeline business to Antin Infrastructure Partners.
  • MetLife, Inc. on the tax aspects of the disposal of MetLife Assurance Limited (a leading specialist bulk annuity pension provider, with approximately GBP 3bn in assets under management) to Rothesay Life Limited.
  • Unipapel on the acquisition of the Spicers group of companies from DS Smith, the partition of the continental European and UK/Irish businesses and simultaneous sale of the UK/Irish businesses to private equity fund Better Capital.
  • Diageo on the UK aspects of the sale of its major wine interests in an agreement with Treasury Wine Estates relating to the US based Chateau and Estate Wines and the UK based Percy Fox businesses for a consideration of USD 552m.
  • Viatel on the sale of its infrastructure and non-Irish enterprise businesses to Zayo Group Holdings, Inc. for approximately EUR 95m involving multiple sellers and a target group covering Ireland, Belgium, UK, France, Netherlands, Germany and Switzerland.
  • LRG on the sale of a portfolio of 18 full-service UK hotels to Cerberus Capital Management via a combination of asset and share sales and the sale of a portfolio of 21 UK hotels to Kew Green Hotels.
  • Aviva Investors on a groundbreaking transaction to provide GBP £36m of funding for a new energy innovation centre for Cambridge University Hospitals NHS Foundation Trust at Addenbrooke's Hospital.
  • A local Education Partnership (the Thames Partnership for Learning Regeneration) in relation to the innovative Barking and Dagenham social housing project, which won the award for "Best Alternative Deal Structure" at the Partnerships Awards 2013.
  • Various financial institutions on tax efficient methods of dealing with outstanding debt on the refinancing or insolvency of debtors and advising on the tax implications of various borrower restructuring arrangements.
  • Various financial institutions in relation to various (UK and multi-jurisdiction) leasing and structured finance transactions involving shares, securities, real estate, aircraft, ships and films.
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Memberships & Roles

  • Member, the PPP Forum tax group.
  • Member, The Infrastructure Forum tax group.
  • Member, the Association of the British Pharmaceutical Industry tax committee.
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Education

  • 1995 - BA (Hons) Law, Cambridge University, Cambridge
  • 1996 - LPC, College of Law, York
  • 1999 - MA, Cambridge University, Cambridge
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Feed

07/03/2024
Introduction to Crypto-Asset Reporting Framework, the new OECD international...
In 2023, the OECD conducted its first comprehensive review of the Common Reporting Standard (“CRS”) since CRS was adopted by the OECD in 2014. This has resulted in amendments in two key areas:(A)...
07/02/2024
CMS UK Tax Disputes Digest (Winter 2024)
Welcome to the winter 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel...
23/10/2023
CMS UK Tax Disputes Digest (Autumn 2023)
Welcome to the autumn 2023 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel...
03/07/2023
CMS UK Tax Disputes Digest - Summer 2023
Welcome to the Summer 2023 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel...
24/03/2023
CMS UK Tax Disputes Digest (March 2023)
Welcome to the March 2023 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel...
15/12/2022
Tax treatment of re-insurance of BLAGAB – changes with immediate effect
On 15 December 2022, tax changes have been announced, which have immediate effect, which apply to insurers which write, acquire or re-insure basic life annuity and general assurance business (‘BLAGAB’)...
30/11/2022
UK Tax Disputes Digest
Welcome to the autumn 2022 edition of our UK Tax Disputes Digest: a high-level summary for heads of tax, finance directors, general counsel and other in-house professionals of key developments in contentious...
30/11/2022
CMS Tax Disputes Digest (November 2022)
Welcome to the autumn 2022 edition of our UK Tax Disputes Digest: a high-level summary for heads of tax, finance directors, general counsel and other in-house professionals of key developments in contentious...
23/08/2022
CMS UK Tax Disputes Digest (August 2022)
Welcome to the summer (and very first) edition of our UK Tax Disputes Digest: a high-level summary for general counsel, heads of tax and other in-house professionals of some of the key tax cases over...
22/08/2022
UK Tax Disputes Digest
Welcome to the summer (and very first) edition of our UK Tax Dis­putes Di­gest: a high-level summary for general counsel, heads of tax and other in-house professionals of some of the key tax cases over...
25/10/2021
Tax Risk Evaluation and Mitigation Schemes
The tax climate in the UK has changed significantly in recent years and HMRC are increasingly likely to challenge arrangements they regard as excessive tax planning.  There are also increasing obligations to disclose information about certain transactions or arrangements as they arise, creating further administrative burden on all taxpayers (including those who may not even be knowingly engaging in tax avoidance).
25/10/2021
Tax-related (Commercial) Disputes
Tax disputes are not restricted to disputes with tax authorities.  Where unexpected tax liabilities and penalties arise, taxpayers will need to determine whether they are able to recover any associated losses from third parties (for example, under warranties and indemnities).