Authorities challenge real estate loss deduction

News, information

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

Consideration paid for a TOB in a Japanese minority squeeze out

December 2, 2010  |  Court  |  No Comments

News, information

On 27 October the First Civil Division of the Tokyo High Court issued a decision concerning the basis of calculation of the consideration paid to acquire the shares of minority shareholders (below, the ‘Minority’) post a public offering to take Cybird Holdings, (below ‘Holdings’) private as part of a management buyout transaction. Read More

The New Saudi Arabia, Japan tax treaty

November 24, 2010  |  Developments, News, Tax Treaties  |  No Comments

News, information

the 15th of November, 2010, Mr. Seiji Maehara for the Government of Japan and Mr. Ibrahim Al-Assaf for the Government of the Kingdom of Saudi Arabia the text of the new double taxation convention between the Government of Japan and the Kingdom of Saudi Arabia (below the ‘Treaty’).  A link to the English text of the Treaty can be found here. Read More

2011 Tax Reform – Direction Unknown

November 19, 2010  |  News, Policy  |  No Comments

News, information

Under the headline “Tax Reform, Direction Unknown” an article published on the 17th of  November 2010 in Japan’s Nikkei Keizai Shimbun reported on difficulties that had entered into the process for setting tax policy in 2011.  The Nikkei noted that this was an opportunity to show real political leadership. Read More

The new Hong Kong, Japan tax treaty

November 10, 2010  |  Developments, News, Tax Treaties  |  No Comments

News, information

On 9 November 2010 the  Secretary for Financial Services and the Treasury of Hong Kong, Professor K C Chan and The Consul-General of Japan in Hong Kong, Mr. Yuji Kumamaru, signed the text of the much anticipated Hong Kong/Japan tax treaty (below the ‘Treaty’). Read More

Individuals becoming non-Japanese resident

November 4, 2010  |  Court, Individual  |  No Comments

Japanese judicial decisions

The Japanese Tax Tribunal web site summarizes the results of an appeal dated 10 September 2009 concerning tax residence for an individual who went to work outside Japan while his family, whom he visited relatively regularly, remained living in Japan. Read More

Proposed extension of period to re-file a tax repayment claim

November 2, 2010  |  Developments, News  |  No Comments

News, information

On 2 November 2010 the Nikkei Keizai Shimbun reported on a 2011 tax reform proposal to extend the period allowed for tax payers to resubmit tax returns that request a repayment of tax. Read More

Japanese tax preference zones?

October 27, 2010  |  News, Policy  |  No Comments

News, information

On 26 October 2010 the Nikkei Keizai Shimbun reported on proposals to introduce into Japan tax preference zones (in Japanese.’総合特区’ or ‘sougou tock’ translated below as ‘Comprehensive Special Zones’) that give preferential tax treatment to certain industries Read More

Corporate tax rate reduction and other 2011 tax proposals

October 26, 2010  |  Developments, News, Policy, Uncategorized  |  No Comments

News, information

On 26 and 25 October the Nikkei Keizai Shinbum reported on the status of a number of 2011 tax reform proposes following the most recent meeting of the Japanese Tax Commission (税制調査会 link in Japanese) on 25 October.  Key points of discussion included lowering the Japanese corporate tax rate Read More

Restatement of accounts and tax deductibility of expenses

October 23, 2010  |  Court, News  |  No Comments

Japanese judicial decisions

The Tokyo District Court (in Japanese commonly referred to as ‘東京地裁’) recently issued a decision in a case involving a plaintiff that had improperly capitalized costs into inventory in a prior financial year and then claimed a tax deduction for the write off of those costs in the subsequent financial year under appeal. Read More