"Taxation related to triangular mergers in response to the latest revisions in 2019"

Authors: Hidehiro Utsumi
Magazine/Book:National tax bulletin
Practice: Tax Consulting
Date of publication: April, 2007

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Pitfalls in applying tax haven countermeasures in M&A- Double taxation risks caused by initial filing requirements
2020.09.15
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2017.09.01
”Tightening of Export Restrictions under the Amended Foreign Exchange and Foreign Trade Act,”
2016.07.01
”The Recent Trends in Tax-Related Problems in India and Indonesia,”
2016.02.01
"M&A and related trade issues based on the TPP,"
2015.11.01
"Responsibilities of Attorneys in Trade and Export Control,"
2014.10.01
“50 Important Points Certified Public Tax Accountants should Know Regarding Disputes on Tax Matters and Claims for Damages against Tax Accountants”
2014.01.01
"How to deal with tax troubles in M&A"
2012.09.01
"Latest Situation of Anti-Dumping Tariffs as Seen by Companies - Including Measures for Imposition of Tariffs Abroad"
2011.01.01
“Strategically Addressing Tax Investigations and Disputes – From the Basics to the Latest Practice”
2010.04.01
"A Dictionary of Frequently Used M&A Words for All Professionals Involved in M&A (The Latest Trends),"
2009.08.01
"M&A Comprehensive Map-Characteristics and Points to Note of Each Method from Scheduling-"
2009.06.01
"Overseas Debt Collection: The Greatest Defense Is Preparing"
2009.02.01
"Recent Legal and Tax Issues on M&A Transactions,"
2009.02.01
"How to Collect Claims from Overseas Companies,"
2008.12.01
"Emergency Measures to Rescue Financial Institutions in the US,"
2008.12.01
"Emergency Measures to Rescue Financial Institutions in the UK,"
2008.11.01
"Formulation of Financial Institution Rescue Measures in the United States"
2008.11.01
"Development of Financial Institution Rescue Measures in the UK"
2007.06.01
"Revisiting Corporate Governance"
2007.02.01
"Foreign Tax Credits for Investing in Entities Treated Differently in Both Countries"
2006.12.01
"Taxation related to the establishment of a foreign trust (so-called personal trust) by a resident individual"
2006.12.01
"Important Points Regarding Withholding Tax in International Taxation"
2006.09.01
"Taxation of Japanese Equity Investment Funds"
2006.05.01
"Taxation in Japan for non-resident (individual) Real Estate Investment in Japan"
2006.02.01
"Regarding taxation in Japan related to stock options received from foreign parent companies"
2006.01.01
"Taxation on Sale and Lease of Real Estate by Foreign Corporation Conducting International Transport Business,"
2006.01.01
"An Outline Of The Japanese Government’s 2006 Tax Reform Proposals"
2005.12.01
"Transfer of shares similar to business transfer and debt/equity swap"
2005.11.01
"Realizing Corporate Governance to Enhance Corporate Value and Points to Keep in Mind for Doing so"
2005.10.01
"Determination of Resident/Non-resident Status and Tax Haven Taxation,"
2005.09.01
"Framework of Internal Systems of Control with Company Law,"
2005.09.01
"Revision of the Regulations regarding Quasi-foreign Companies,"
2005.03.01
"Increasingly Tightening Insider Trading Regulations,"
2005.01.01
"Important points to note when preserving documents and drafting contracts under the transfer pricing tax system"
2004.01.01
"Corporate Governance - Business Approach for Enhancing Corporate Value,"
2003.04.01
"Tax and Legal Affairs Related to Withholding Taxation in International Transactions" (3 issues in total)
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PLC Global Counsel Handbooks - Tax Law 2003 (Japan section)
2003.01.01
"Q&A on Reorganization of US Branches and Subsidiaries - Procedures, Tax/Legal Issues under Local Legislation,"
2002.10.01
"US-Japan Comparison - Tax and Legal Matters of Financial Instruments,"
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"Tax Q&A on Corporate Restructuring Across Japan and the US"
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"Possibility of Use of Foreign Tax Credit Margins -Based on Recent High Court Cases-"

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2024.09.10
Pitfalls in applying tax haven countermeasures in M&A- Double taxation risks caused by initial filing requirements
2020.09.15
”Deductibility of advisor costs in M&A and how to deal with tax audits”
2017.06.01
Lawyers Guide - Labor/Tax edition A Supplementary Volume to Business Law Journal No.113 (August 2017)
2014.10.01
“50 Important Points Certified Public Tax Accountants should Know Regarding Disputes on Tax Matters and Claims for Damages against Tax Accountants”
2014.01.01
"How to deal with tax troubles in M&A"
2011.01.01
“Strategically Addressing Tax Investigations and Disputes – From the Basics to the Latest Practice”
2009.02.01
"Recent Legal and Tax Issues on M&A Transactions,"
2007.04.01
"Taxation related to triangular mergers in response to the latest revisions in 2019"
2007.02.01
"Foreign Tax Credits for Investing in Entities Treated Differently in Both Countries"
2006.12.01
"Taxation related to the establishment of a foreign trust (so-called personal trust) by a resident individual"
2006.12.01
"Important Points Regarding Withholding Tax in International Taxation"
2006.09.01
"Taxation of Japanese Equity Investment Funds"
2006.05.01
"Taxation in Japan for non-resident (individual) Real Estate Investment in Japan"
2006.02.01
"Regarding taxation in Japan related to stock options received from foreign parent companies"
2006.01.01
"Taxation on Sale and Lease of Real Estate by Foreign Corporation Conducting International Transport Business,"
2006.01.01
"An Outline Of The Japanese Government’s 2006 Tax Reform Proposals"
2005.10.01
"Determination of Resident/Non-resident Status and Tax Haven Taxation,"
2005.01.01
"Important points to note when preserving documents and drafting contracts under the transfer pricing tax system"
2003.04.01
"Tax and Legal Affairs Related to Withholding Taxation in International Transactions" (3 issues in total)
2003.01.01
PLC Global Counsel Handbooks - Tax Law 2003 (Japan section)
2003.01.01
"Q&A on Reorganization of US Branches and Subsidiaries - Procedures, Tax/Legal Issues under Local Legislation,"
2002.10.01
"US-Japan Comparison - Tax and Legal Matters of Financial Instruments,"
2002.09.01
"Tax Q&A on Corporate Restructuring Across Japan and the US"
2002.08.01
"Possibility of Use of Foreign Tax Credit Margins -Based on Recent High Court Cases-"

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