In every single transaction, whether it is domestic or transnational, tax issues always loom in the background. Our tax practice group provides comprehensive tax services for solving those looming tax issues.
We are proud that, in a crowded international field, we have established a solid record and foundation for offering uninterrupted full international legal services. We have maintained a scrupulously high reputation with foreign law firms and tax firms, through notices of our annual reviews conducted by the headquarters of those networks.
Based on this history, and taking into account increased attention to the place of tax issues within international corporate legal strategies, we have specialized our services for the realm of “international taxation”. We want to be the best firm in Japan for international clients who need total services combining tax matters and legal matters (especially in transnational M&As). We also aim to provide tax counseling services to our clients taking into account the threats (or opportunities) of dispute settlements and litigation involving tax issues.
We have experience and expertise providing comprehensive tax services, including all of the areas below.
International Tax Strategies
We specializes in developing Japanese tax strategies for international clients to maximize efficiencies in their Japanese operations. Such strategies include not only plans for corporate income tax but also withholding and consumption tax strategies.
Working with our network of global firms, we advise on the formation, management and restructuring of global supply-chains for multinational companies based in Japan.
In recent years, tax litigation in Japan has turned decidedly against cases brought by taxpayers. However, within that ocean of bad news, the courts have been issuing important judgments in favor of taxpayers based on interpretations of the law that take business conditions into consideration. In particular, the courts have shown an unwillingness to allow the tax authorities to operate arbitrary tax laws.
We would like to actively help taxpayers in this field. We have a tax specialist who, despite the prevailing winds, has kept to winning a tax litigation suit all the way to the Supreme Court of Japan. And we are prepared to make flexible cost proposals when a major obstacle to tax litigation arises to be challenged.
We has volumes of expertise dealing with the tax issues surrounding M&As, broken down into experience with tax rules applicable to corporate restructurings and a deep understanding of the civil rehabilitation law and the corporate reorganization law.
As just one example of which we are especially proud, our tax group successfully strategized and guided a U.S. based company in the financial industry in its M&A strategy in which the target was a Japanese company, getting excellent results through the key factor of the tax loss carry-forward of the target.
Also high on our list of achievements is our significant experience providing superior tax advisory services related to international equipment leases involving foreign banks and Japanese leasing companies.