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
The Japanese tax law concerning Japanese civil law partnerships (in Japanese nin’i kumiai and below ‘NKs’) includes anti-avoidance provisions that can apply to deny the deduction of tax losses arising from an NK under circumstances where, generally speaking, the investment is passive and there are actual or substantive limits to the NK investor’s economic exposure to the underlying NK investments. Read More
This article discusses the basic Japanese accounting treatment of membership of Japanese civil law partnership, in Japanese a nin’i kumiai and below an NK.
An overview of the legal aspects of an NK arrangement can be found in this article, which also includes defined terms or abbreviations used here.
A description of the tax treatment can be found in this article.
For Japanese tax purposes Japanese civil law partnerships (in Japanese nin’i kumiai, referred to below as ‘NK’s) are treated as fiscally transparent.
NKs themselves are not taxed as separate entities. Instead, the members of the NK are subject to taxation on the income treated as attributable to them. Read More