Tax
Business today is defined by the increasing importance not only of avoiding legal risks, but of exhaustively considering how to achieve the best tax outcomes in all transactions, and of reducing tax risks as much as possible to avoid inviting unexpected difficulties in the future.
The Kitahama Partners tax team is made up of attorneys who are Certified Tax Accountants and attorneys with secondment experience at the National Tax Tribunal. We offer a wide range of general tax services and have a robust and diverse track record in areas involving tax advice and planning for various transactions, participation in tax investigations, and tax disputes caused by differences of opinion with tax authorities.
We provide optimal advice from a legal and tax standpoint for various transactions in all industries, including corporate acquisitions, organizational restructuring, fund procurement, and investment in real property and financial assets. Our services in these areas include the following.
- Handling of tax investigations, both prior to and during the investigation
- Handling of appeals and claims for correction
- Handling of tax disputes
- Comprehensive provision of legal and tax services for managerial decisions
- Comprehensive provision of legal and tax services for inheritance and business succession
- Comprehensive provision of legal and tax services for M&A and business restructuring
- Comprehensive handling of legal and tax services for medical corporations and social welfare organizations
- Consultation for and handling of tax accountant liability
Our attorneys also dedicate their skills to estate planning related to trusts, wills and succession for high net worth individuals, and to tax planning related to asset management and business succession domestically and overseas, which skills are informed by a wealth of experience handling tax investigations and disputes. The following are examples of some of the cases we have handled in the past.
- Cases where real property tax was partially revoked in regard to buildings planned for demolition
- Cases where tax investigations have found that international transactions are not subject to consumption tax
- Cases disputing whether asbestos abatement costs were eligible for casualty loss deduction
- Cases where tax investigations caused tax authorities to abandon levying heavy additional taxes in regard to cut-off errors
- Cases where tax investigations caused tax authorities to abandon levying heavy additional taxes in regard to price adjustments
- Cases where tax investigations resulted in the substantial reduction of inheritance tax back payments
- Tax investigation negotiations and formal objection procedures in regard to stock option valuation
- Tax cases related to consideration for the development of new products
- Cases related to import consumption taxes for recycling seals
- Cases disputing, and resulting in the full revocation of, the levying of heavy additional taxes for reason of intentional income concealment
- Preparation of opinions related to handling of consumption taxes on insurance proceeds payments
- Preparation of opinions related to tax-free exports
- Preparation of opinions related to interest on secured loan claims
- Business succession cases for Certified Tax Accountant offices
- National compensation claim cases
- Compensation claim cases
- Supreme Court decisions related to savings
- Inspections, criminal public trial proceedings
