image of Louisa WuLouisa Wu

Clayton Utz Special Counsel , Sydney T +61 2 9353 4611 https://www.claytonutz.com

Known for her clear and pragmatic advice, Louisa specialises in Australian and international tax law and has over 20 years of transactional experience in corporate and banking and finance work.  

She has advised a broad range of Australian and international clients across numerous sectors, including the financial services, extractive, and manufacturing industries, who appreciate her skills in explaining complex legal tax principles in a simple and accessible way.

She has special technical expertise in securitisation transactions, and is a member of the Australian Securitisation Forum's Accounting and Tax Subcommittee.

Louisa has also assisted clients with their private ruling requests and tax audits and dispute resolution issues, including liaising with the Australian Taxation Office to achieve successful client outcomes on a timely basis.

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Expertise

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Taxation

Australia Pacific LNG (APLNG): Louisa advised on the tax aspects of the US$8.5 billion project finance facility for the development of the APLNG coal seam gas project in Queensland, Australia and advised on a US$1.4 billion note issuance.

Barrick Gold Corporation: Louisa is a trusted adviser to Barrick Gold Corporation, the world’s largest gold miner.  She has advised on transactions including:

  • the sale for $1.1 billion of Barrick's joint venture interest in the Kalgoorlie superpit to Saracen Minerals;
  • the sale or partial sale of Australian mining interests, including the Cowal Coal mine and Porgera in PNG;
  • as Australian counsel to Barrick Gold Corporation, on its successful A$7.1 billion bid to acquire ASX and TSX listed Equinox Minerals Limited; and
  • on its raising US$1.25 billion in two tranches pursuant to Rule 144A from the US capital markets.

Employee share schemes: Louisa advised on the income tax implications of various employee share and option schemes for both employers and participating employees.

High net worth individuals and family groups: Louisa has advised a number of high net worth individuals and family groups on their tax affairs, including in relation to the small business capital gains tax concessions.

Not for profit sector: Louisa advised numerous charities, including obtaining test case funding for The Hunger Project Australia and successfully acting for The Hunger Project Australia in the Federal Court and Full Federal Court in a precedential case which clarified the meaning of “public benevolent institution”. Other charities which she has advised include the Charlie Teo Foundation, Street Side Medics, Allergy & Anaphylaxis Australia, Cancer Council NSW, the Nelune Foundation, Sunnyfield and UNICEF.

Western Sydney University: Louisa advised in relation to campus redevelopment initiatives.

Reinsurance (various clients): Louisa advised in relation to the income tax implications of various reinsurance arrangements.


Corporate / M&A

Gerbr Knauf KG: Louisa advised Germany's Gerbr Knauf KG on a series of divestments. 

Macquarie Bank: Louisa advised on the income tax implications of Macquarie's acquisition of the Esanda dealer finance portfolio from ANZ for $8.23 billion.

See Taxation

Taxation Disputes

ASX listed company: Louisa prepared submissions to the ATO and participated in negotiations with the ATO in respect of a significant tax dispute.

Australian Government subsidiary: Louisa advised in relation to the income tax treatment of almost $1 billion of government grants in a dispute with the ATO. The dispute was successfully resolved in mediation.

Confidential matter relating to IP transfer issues: Louisa applied for a private tax ruling in relation to international IP transfer issues for a multi-billion dollar transaction.

See Taxation Disputes

Banking and Finance

Australian financial institutions (various clients): Louisa advised on wealth management compensation issues.

Singtel Optus: Louisa advised Singtel Optus, Australia's second largest telecommunications company, on its issue of US$500 million 10 year Regulation S EMTNs.

See Banking and Finance

Securitisation

She has advised on numerous securitisation transactions including for AMP, Athena, Bluestone, CUA, Flexigroup, ING, Macquarie, National Australia Bank, Resimac, and Westpac.

Louisa is a recognised expert in securitisation transactions.  This has included providing tax advice on structuring issues and public debt offerings in the debt capital markets.

Louisa is an Accounting and Tax Subcommittee member of the Australian Securitisation Forum.

See Securitisation

Debt Capital Markets and Securities

Louisa has deep experience in advising on the tax aspects of public debt offerings in the debt capital markets. The clients she has advised include large Australian corporates, as well as numerous Australian and foreign lenders and funds.

See Debt Capital Markets and Securities

Knowledge

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