Omer Harel

Omer frequently advises issuers and underwriters on the U.S. tax aspects of various securities offerings such as initial public offerings and other equity offerings, investment grade, high yield and convertible debt issuances, asset-backed securitizations and various liability management transactions (exchange offers, tender offers and consent solicitations) with a particular focus on transactions involving non-U.S. issuers or U.S. issuers that are members of non-U.S. parented groups. Omer also frequently advises on the U.S. tax aspects of cross-border financing arrangements, structured products and derivatives, cross-border mergers and acquisitions, joint ventures, private equity portfolio investments and restructurings.

Work highlights

Omer has advised on the tax aspects of many market-leading transactions. These include advising:

Capital Markets

• Puig on the U.S. tax aspects of its €2.9 billion Spanish IPO and Rule 144A offering.
• The initial purchasers on the U.S. tax aspects of United Group €1.7 high-yield refinancing comprising of four tranches of senior secured and PIK notes.
• The underwriters on the U.S. tax aspects of the c.€2.3 IPO and Rule 144A offering of CVC Capital Partners and listing on Euronext Amsterdam.
• Holcim on the U.S. tax aspects of its exchange offer for six series of outstanding bonds originally issued by its subsidiaries for new bonds of corresponding maturity guaranteed by Amrize in connection with Holcim’s spin-off of its North American business.

Securitizations

• Citi as the arranger and sole lead manager on the U.S. tax aspects of a landmark securitization deal involving a large portfolio of UK equity release mortgages.
• Cerberus European Residential Holdings B.V. as the sponsor on the U.S. tax aspects of an RMBS transaction securitizing a portfolio of residential mortgage loans.

Finance and Banking

• Onex Partners on the U.S. tax aspects of its acquisition finance in connection with the acquisition of Fischback KG.
• Goldman Sachs on the U.S. tax aspects of its debt financing for the public offer for L’Occitane.

Mergers and Acquisitions

• Getir on the U.S. tax aspects of the acquisition of online grocery company FreshDirect Inc. from Ahold Delhaize USA.
• AXA IM Prime on the U.S. tax aspects of its acquisition of a minority stake in Hayfin, a leading European alternative asset management company, jointly with Mubadala Investment Company.

Prior to joining Linklaters, Omer worked for over a decade in the New York and London offices of Davis Polk & Wardwell LLP. Omer also previously worked as an associate trainee at S. Horowitz in Israel.

Further work highlights

Capital Markets

• Almaviva on the U.S. tax aspects of its €725 million senior secured fixed rate notes offering.
• Royalty Pharma plc on the U.S. tax aspects of its $2.5 billion SEC-registered Up-C IPO and $6 billion 144A/Regulation S senior notes.*
• The joint book-running managers on the U.S. tax aspects of iQIYI concurrent $1.5 billion SEC-registered convertible notes and ADS offering.* 

• The dealer managers on the U.S. tax aspects of TIM €5 billion equivalent concurrent exchange offers.

Securitizations

• Citi as the sponsor and the arranger on the U.S. tax aspects of an RMBS transaction securitizing a portfolio of £2 billion residential mortgage loans.
• The co-arrangers on the U.S. tax aspects of an RMBS offering by Together Asset Backed Securitisation 2024-1ST1 PLC involving a portfolio of second and third ranking mortgages.

Finance and Banking

• Barclays and BNP Paribas on the U.S. tax aspects of the $115 million bridge term loan facility for the Watches of Switzerland Group’s acquisition of Roberto Coin Inc.
• The lenders to Stahl on the U.S. tax aspects of a refinancing of its existing facilities.
• The lenders to IKS Health on the U.S. tax aspects of the financing of IKS Health’s acquisition of AQuity Solutions.
• An ad hoc group of senior secured lenders and DIP lenders on the U.S. tax aspects of Expro Group’s pre-packaged bankruptcy.*

Mergers and Acquisitions

• e& on the U.S. tax aspects of its $400 million investment in exchange for a majority stake in Careem’s Super App.
• The Special Committee of the Board of Directors of Zhangmen Education in connection with its going private transaction.
• Sibanye-Stillwater on the U.S. tax aspects of its joint venture with ioneer.*
• Heineken N.V. on the tax aspects of a joint venture with China Resources Enterprises.*
• Tencent on the tax aspects of its strategic investment in JD.Com and going private transaction of Sogou Inc.*

*Matters handled prior to joining Linklaters.

• Taxation of Investments in U.S. Real Estate (Hebrew) Missim Kaf-Vav/3 A-19 · Jun 1, 2012
• Rethinking the U.S. Estate Tax on Nonresident Aliens 64 Tax Notes Int'l 77, Oct 3, 2011