The following is based on what we prepared for Legal 500, slightly supplemented:
Tax: the firm advises on the tax aspects of mergers, corporate splits, spin-offs, joint-ventures and acquisitions and on investment structuring. Our team also advises on the tax aspects of securities offerings, commercial lending transactions and other corporate commercial transactions (including in relation to permanent establishment related risks and employee compensation). It also assists clients with their tax controversies and disputes before the Japanese courts and the National Tax Tribunal.
Publications Related to Tax
Sato Shuji authored an article entitled "Impact of Judgement Pronouncing that Order for Enforcement of the Corporation Tax Act is Illegal and Invalid" which appears in September 2018 issue (VOL.66/NO.9) of Zeimu Kouhou.
A book entitled "Corporate Legal Strategy for Tax Compliance" is published by Minjihokenkyukai Co., Ltd., which is edited by the Research Division of Tax Suit Practice that forms part of the Comprehensive Legal Study Center of the Dai-ichi Tokyo Bar Association. Wakabayashi Shigeo, the President of the Dai-ichi Tokyo Bar Association, writes a preface for this book. In addition, Sato Shuji, as a member of the editorial committee, and Suzuki Masato and Mutou Yuuki, as authors, contribute to the publication.
Yamada Yuta's commentary titled " JFTC Makes a Recommendation to Mynavi Corporation and Mynavi Publishing Corporation" is available on the Shoji Homu Portal Site.
- YAMADA Yuta
Sato Shuji authored an article entitled "Quick Report of Tax Precedents: A Case in which Provisions of an Ordinance regarding Deemed Dividends were Determined as Illegal/Void" which appears in Jurist No. 1521.
Sato Shuji's article titled "Summary of Case on Losing Horse Race Tickets - 'Collaboration' of Tax and Legal Affairs is Needed" appears in June 2018 issue of Zeimu Koho.
Lectures, Seminars and Conferences Related to Tax
Sato Shuji delivered a lecture concerning taxation on reorganization in the Advanced Course (54th) of training in National Tax College of National Tax Agency.
Sato Shuji and Muto Yuuki jointly delivered lectures entitled respectively "Tax Cases and Supreme Court - Denso Case as Example" and "Revenue Recognition and Generally Accepted Accounting Principles" in a round-table conference by members of the Japan Tax Association held at the Industry Club of Japan.
Sato Shuji will deliver a lecture entitled "Consideration of Taxpayers Winning Cases in Tax Suits - How Plaintiffs Won Lawsuits against National Tax Authorities" at a seminar hosted by FN Holding on October 14.
Sato Shuji will deliver a lecture entitled "Analysis of Taxpayers Winning Cases in Recent Tax Suits - Explanation on Handling of Tax Investigations, etc. Based on My Experience as an Appeals Judge of National Tax Tribunal Appointed from Private Sector” at the seminar hosted by Keiei Chosa Kenkyukai on May 11, 2016.
News Related to Tax
Sato Shuji's comment was introduced in the article titled "Transfer Pricing Taxation - National Tax Agency Steers Toward Communication Strategy, While Businesses Remain Skeptical" in the morning edition of the Nikkei newspaper on November 27, 2017.
Sato Shuji participates in Study Group of Financial Taxation System and Numbering System (Chairperson: Morinobu Shigeki, Professor of Chuo Law School), which releases a report entitled “ Utilization of Social Security/Taxation Number (My Number) System and IRA in Japan.”
Mutou Yuuki has been seconded to Examination Division I of Tokyo Regional Taxation Bureau as a fixed-term government employee as of July 10.
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