Tax Disputes

We have a long history of experience in litigation and other forms of dispute resolution, and our expertise extends to the area of tax disputes. We are particularly active in advising clients in responding to tax investigations.

Our firm is structured in a way that enables and encourages our lawyers primarily practicing tax law to work as a team with our lawyers from many other Practice Groups that become relevant in tax litigation (for example, Intellectual Property, Finance, and M&A), which facilitates our smooth provision of comprehensive legal services and enables us to provide clients with successful litigation strategies. We have utilized our strengths to achieve an excellent track record in this area of law, as shown by the number of tax disputes in which we have achieved favorable outcomes on behalf of taxpayers.

Another important focus of our practice is on tax investigations. Our services in this field include the provision of advice at various stages of tax investigations, such as the planning of strategies in anticipation of litigation; legal discussions and resolution-oriented negotiations with investigators; and the submission of memorandums to the tax authorities.

Tax Disputes:People

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Tax Disputes:News

Works
MHM obtains a final judgment in favor of the taxpayer in tax litigation regarding the reorganization of its subsidiary
Works
Representing a client, MHM obtains a National Tax Tribunal decision in favor of the client, ordering rescission of a tax authority’s disposition for taxation in full

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Tax Disputes:Publications

Magazine Article
"Application of the CFC Rules to Captives - Interpretation of 'Subject of Insurance' (Tokyo High Court Decision dated September 14, 2022)"
Magazine Article
"Applicability of the Six General Provisions for Valuation of Unlisted Shares Based on the 2023 Supreme Court Decision (Based on the Case of Chuoh Publishing Holdings)"
Book
”Comprehensive Analysis of M&A Laws of Japan, 2nd edition”
Magazine Article
”Determination of Economic Rationality in Corporate Reorganization”
Magazine Article
"Aggregation of losses arising from 'Miscellaneous Income' with other types of income"

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