One minute with Graham Iversen, Partner at Greenberg Traurig.
What’s keeping you busy at work?
The usual stream of corporate and financing transactions, including some that will be quite eye-catching if they happen (which remains to be seen).
If you could make one change to a tax law or practice, what would it be?
Ideally, the UK needs a complete overhaul of HMRC’s powers and practices in relation to pre-transaction clearances. I realise that there are resource and cost implications, but giving HMRC greater powers and resources with which to give pre-transaction clearances would make a big difference to the UK as a place to do business – far more than most substantive tax law changes that are mooted. Clients trying to do transactions tend to value certainty or predictability of outcome over most things, even if the thing that’s certain is that there will be a tax charge on a particular transactional step – at least clients can model and price for that.
What do you know now that you wish you’d known at the start of your career?
That Malcom Gladwell’s famous rule that it takes 10,000 hours to master a subject doesn’t hold true for tax – I think that it’s a multiple of that for tax work! Even those practitioners who make it look easy don’t really find it easy, I think – there’s a lot going on behind the scenes. I remember as a young tax lawyer being daunted by the realisation of how little I knew, how much there was to learn and by the protean, constantly changing nature of the subject. But it’s like that for everyone – and it’s important to realise that everyone finds it hard sometimes and that very few people really know as much as they appear or pretend to know. Any young tax lawyer should read into and think about any issue as deeply as time and transactional circumstances will permit – it will be worth it in the long run. Ultimately, getting to grips with the subject and being able to apply it to difficult, big and/or fast-moving transactions is very rewarding.
What are your career highlights?
There have been a lot of interesting, high-octane transactions. But the main highlight has to be the work for HM Treasury acting on the transactions undertaken to preserve the stability of the UK banking system at the height (or depth) of the 2007–2009 financial crisis, including the recapitalisations and restructurings of various banks and the creation of HM Treasury’s Asset Protection Scheme, which required the design of a complex and novel scheme, including allowing banks to ‘pay’ for access to the scheme by using their tax assets. A nerve-wracking, once-in-a lifetime set of transactions (made all the more stressful by the fact that my own life’s savings were with the RBS group when the crisis began, so the risk of seeing the UK banking system implode and my own savings disappear seemed all too vivid).
Are any new rules causing a particular problem in practice?
Pillar Two is of course going to be a seismic change in the international tax landscape. It is making some clients think hard about their group structures and the location of their operations. There still seems to be a quite a low level of awareness of the implications outside the tax advisory community, but that will have to change soon and rapidly.
And finally, you might not know this about me but...
I’ve spent so much of my professional life navigating the rigours of difficult law and commercial transactions that I’m generally happiest when doing things that are completely the opposite. Comedy gigs, particularly work-in-progress shows in intimate venues seeing comedians try out new material, are a particular favourite.
One minute with Graham Iversen, Partner at Greenberg Traurig.
What’s keeping you busy at work?
The usual stream of corporate and financing transactions, including some that will be quite eye-catching if they happen (which remains to be seen).
If you could make one change to a tax law or practice, what would it be?
Ideally, the UK needs a complete overhaul of HMRC’s powers and practices in relation to pre-transaction clearances. I realise that there are resource and cost implications, but giving HMRC greater powers and resources with which to give pre-transaction clearances would make a big difference to the UK as a place to do business – far more than most substantive tax law changes that are mooted. Clients trying to do transactions tend to value certainty or predictability of outcome over most things, even if the thing that’s certain is that there will be a tax charge on a particular transactional step – at least clients can model and price for that.
What do you know now that you wish you’d known at the start of your career?
That Malcom Gladwell’s famous rule that it takes 10,000 hours to master a subject doesn’t hold true for tax – I think that it’s a multiple of that for tax work! Even those practitioners who make it look easy don’t really find it easy, I think – there’s a lot going on behind the scenes. I remember as a young tax lawyer being daunted by the realisation of how little I knew, how much there was to learn and by the protean, constantly changing nature of the subject. But it’s like that for everyone – and it’s important to realise that everyone finds it hard sometimes and that very few people really know as much as they appear or pretend to know. Any young tax lawyer should read into and think about any issue as deeply as time and transactional circumstances will permit – it will be worth it in the long run. Ultimately, getting to grips with the subject and being able to apply it to difficult, big and/or fast-moving transactions is very rewarding.
What are your career highlights?
There have been a lot of interesting, high-octane transactions. But the main highlight has to be the work for HM Treasury acting on the transactions undertaken to preserve the stability of the UK banking system at the height (or depth) of the 2007–2009 financial crisis, including the recapitalisations and restructurings of various banks and the creation of HM Treasury’s Asset Protection Scheme, which required the design of a complex and novel scheme, including allowing banks to ‘pay’ for access to the scheme by using their tax assets. A nerve-wracking, once-in-a lifetime set of transactions (made all the more stressful by the fact that my own life’s savings were with the RBS group when the crisis began, so the risk of seeing the UK banking system implode and my own savings disappear seemed all too vivid).
Are any new rules causing a particular problem in practice?
Pillar Two is of course going to be a seismic change in the international tax landscape. It is making some clients think hard about their group structures and the location of their operations. There still seems to be a quite a low level of awareness of the implications outside the tax advisory community, but that will have to change soon and rapidly.
And finally, you might not know this about me but...
I’ve spent so much of my professional life navigating the rigours of difficult law and commercial transactions that I’m generally happiest when doing things that are completely the opposite. Comedy gigs, particularly work-in-progress shows in intimate venues seeing comedians try out new material, are a particular favourite.
