In recent months the Japanese specialist tax press has reported on the increasing number of Japanese tax audits focusing on Japanese tax preferred corporate reorganizations (below “Japanese TPCRs’) . Please see the corporate reorganization section for details Read More
On 24 July 2011 the Nikkei newspaper reported on trends in audits of Japanese inheritance tax. The article talked about the increasing number and depth of such inheritance tax audits and explained that it was common for the tax authorities to find under-reported income during such an audit. The article also outlined some of the points that are often examined during an inheritance tax audit as well as providing guidance on how to deal with an audit if one takes place. Read More
On 21 April 2011 the Tokyo High Court handed down a decision concerning whether shares acquired by a Japanese resident individual further to a spin off by an American company should be treated as dividend income for Japanese income tax purposes. Read More
A lady tends to the charcoal brazier in preparation for the tea ceremony.
An issue common to many tax systems is whether a distribution made by a company to its shareholders in respect of their shares should be treated as a return of capital to those shareholders or alternatively as an item of income. Shareholder taxation will, of course, often vary dramatically depending on the characterization of such a distribution as an item of income or return of capital. Read More
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