Authorities challenge real estate loss deduction

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On 5 December 2010 the Asahi Shimbun reported on an investigation by the Tokyo tax authorities into tax relief claimed on losses from a partnership investing in US real estate.  The investors in the partnership (below the ‘Investors’) were, according to the article, a group of around ten former Japanese baseball players Read More

Tax controversy – Denso’s Singapore subsidiary a CFC

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The Asahi Newspaper reported in July 2010 that Denso, the largest automotive parts manufacturer in Japan and part of the Toyota group, had received direction during its last tax audit that the company had under-reported JPY11.4Bn Read More

Tax Controversy – authorities challenge merger qualification

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Softbank’s reported results for the three month period ended 30 June 2010 included JPY26.4Bn in respect of an assessment to taxes raised on its subsidary, Yahoo Japan, received from the Tokyo Regional Tax Bureau (TRTB) on 30 June 2010.  Read More

Tax Controversy – disallowance of related company recharges

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The Asahi Newspaper reported on 11 August 2010 that Hewlett Packard’s Japanese subsidiary (‘Japan HP’) had received an assessment in respect of JPY47Bn (USD550m) unreported income. Read More