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James Morgan

Tax Partner, London

“I provide tax advice on complex corporate structures, with a particular focus on financial institutions, debt funds and alternative credit funds. I use my in-depth knowledge and understanding of clients’ businesses to help develop commercially appropriate solutions.”


Education and qualifications


James has a broad corporate, finance and structuring tax practice, with a particular focus on the taxation of financial institutions, debt funds and alternative credit funds. He has extensive experience in advising banks on the tax and structural issues arising from their capital markets, financing and corporate transactions. In addition, James has advised on a number of group re-organisations driven by structural reform, recovery & resolution and Brexit planning.

More recently, James has advised several alternative credit funds seeking to implement group reorganisations with significant tax and regulatory issues. James has also advised on numerous securitisation and CLO structures. 

James is also developing a Fintech practice and is part of the Linklaters team advising an international consortium of banks on establishing a global blockchain-based trade finance platform.

Having spent eight years as a technical tax expert in the Strategic Transactions Group at Lloyds Banking Group, James brings unique structuring experience and industry insight to the Linklaters team. 

Work highlights

James has advised on a range of complex transactions. Highlights include advising:

  • LBG on its liability management exercise as part of the bank’s £21bn re-capitalisation in December 2009. This included the c.£8.5bn issuance of the UK’s first tax deductible contingent convertible notes
  • LBG on structural reform, compliance with its UK ringfencing obligations, as well as deferred tax asset structures
  • LBG on its acquisition of the Porterbrook rolling stock leasing company as part of a consortium
  • a consortium of banks on development of the global utility settlement coin structure
  • the underwriting banks on the first UK issued AT1 (by CYBG) since the advent of the “hybrid capital instruments” legislation
  • 23 Capital on its group re-organisation, a structured loan to an art gallery group with security taken in the form of art and numerous other issues
  • RB on its group re-organisation
  • Investec on its group re-organisation
  • PwC in relation to the Lehman proceedings
  • Alcentra on several CLO and risk retention structures
  • Revolut on its group re-organisation
  • Cerberus on several portfolio acquisitions and securitisation structures

Education and qualifications

James studied history at Nottingham University.