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 a book review for the publication "Contestation will Make Tax Practice Fairer" (Chuokeizai-sha, Inc.) authored by Kitamura Yutaka which appears in October 2020 issue of of Zeimu Kouhou.
Sato Shuji served as a moderator for the round-table discussion article titled "Common Sense of Prima Facie Evidence with a view to Tax Examinations" which appears in October 2020 issue of of Zeimu Kouhou.
Sato Shuji supervised the publication titled "Legal and Tax Practice of Beneficial Interest Multi-Layered Trust," which is published by Kabushiki Kaisha Nihon Horei.
Hamasaki Yuki's commentary titled "The National Tax Agency Publishes 'Cases of Large Enterprises' Efforts to Enhance Corporate Governance regarding Tax Matters as of June 2020" is available on the Shoji Homu Portal Site.
- HAMASAKI Yuki
Sato Shuji, Hamasaki Yuki, and Noguchi Daisuke co-authored the article titled "Cross-border In-kind Contribution and Taxation of Foreign Partnership Interests - Considering the Judgement Made for the Case of SHIONOGI & CO., LTD at Tokyo District Court", which appears in 837 issue of T&Amaster.
Lectures, Seminars and Conferences Related to Tax
Sato Shuji delivered a lecture titled "How Courts See Tax Cases - The Legal Perspective of Tax Affairs" at the Japan Tax Association.
Speaker： SATO Shuji
Sato Shuji and Mutou Yuuki delivered lectures titled "Trends of Taxpayer Winning Cases: Cases concerning Transfer Pricing Taxation and Capital Transactions" (by Sato Shuji) and "How to Deal with Tax Compliance Issues Revealed by Misconduct" (by Mutou Yuuki) in the seminar hosted by Tax Consulting Firm TRUST.
Sato Shuji and Mutou Yuuki delivered lectures titled "Tips to Handle Tax Investigations Learned from Recent Tax Suits" and "The Latest Trends in Tax Investigations on Large-scale Corporations including Consumer Tax" respectively in the series of lectures titled “Tax Investigations from Lawyers’ Point of View” at Zeimu Kenkyukai.
Sato Shuji delivered a lecture concerning taxation on reorganization in the Advanced Course (54th) of training in National Tax College of National Tax Agency.
Speaker： SATO Shuji
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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the Competition Law
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Corporate Reorganization/ Rehabilitation
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Large-Scale Environmental Litigation