Advised a Japanese public pension fund to withholding tax refund utilizing sovereign tax exemption. He negotiated with the tax authorities in more than 10 countries, and managed to receive a significant amount of withholding tax refund.
Advised a leading Japanese infrastructure company on its US$6 billion acquisition of a US multinational corporation.
Advised a leading Japanese electronics company on its asset acquisition of a business spanning over 44 countries from a US multinational company. The project size was ranked No. 1 in the history of the Japanese tax division.
Advised a Japanese food company on issues related to the Japanese controlled foreign corporate (CFC) rules with its Ireland- and Swiss-based captive reinsurance company, as well as its compliance with the relevant civil and company law requirements. Kenichi further negotiated with tax authorities in Ireland and Switzerland for obtaining advance tax rulings.
Advised an investment company of a Japanese conglomerate investing in Chile on its tax residency change from the Netherlands to Spain in relation to its dividend withholding tax problem in Chile, and negotiated in obtaining advance rulings from Japanese, Dutch, Spanish and Chileans tax authorities. This resulted in a million-dollar dividend withholding tax savings being retained.
Assisted a Japan-based multinational company in obtaining an advance clearance with Japanese tax authorities in relation to its Singapore subsidiary as to whether its intangible development is outside the scope of the Japanese CFC rule.
Advised an Irish subsidiary of a Japanese multinational conglomerate on its global tax structuring in an aircraft leasing project.
Assisted a Japanese multinational conglomerate in obtaining an advance clearance with the Japanese tax authorities, in relation to the deductibility of hundreds of millions of US dollar losses incurred by its Singaporean shipping subsidiary as a result of transferring its vessels to a Panama subsidiary followed by a retrenchment.
Assisted a leading Japanese multinational company in setting up its first full scale tax policy to manage its global operation.
Acted as an international tax advisor for several large scale Japanese multinational companies, and was involved in the day-to-day international tax matters they had been facing.
‘Issues for introducing Pillar 2 into Japanese taxation (from perspectives of interactions between Pillar 2 and existing rules’, The 21 Century Public Policy Institute - 2020, author
‘How Multi-lateral Instruments Influence Japanese Companies’, The 21st Century Public Policy Institute - 2018, author
‘Tax Management System for Japanese Multinational Companies after BEPS’, The 21st Century Public Policy Institute - 2017, author
‘How to set up infrastructure for proper tax compliance in accordance with BEPS’, Ministry of Economy, Trade and Industry - 2015, co-author
‘Cross-Border M&A’, Hitotsubashi Business Review, Toyo Keizai Shimpo-Sha - 2013, co-author
‘How should Japanese companies deal with PE taxation?’, Japan Machinery Association - 2012, co-author
‘CFO Guidebook’, Tokyo Keizai Shimpo-Sha - 2012, co-author
‘Tax Planning for Japanese Corporate Investors in Australia, with an Emphasis on Conceptual Difference in Income between Australia and Japan’, MBA Research Report, University of Queensland - 1994, author
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