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Modern Lectures on Law of Taxation Volume IV: International Taxation

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Modern Lectures on Law of Taxation Volume IV: International Taxation

  "Modern Lectures on the Law of Taxation Volume IV: International Taxation" was published by Nippon Hyoron Sha Co., Ltd.

Takashi Yoneda was the co-editor in chief of the series for this publication with Professor Minoru Nakazato (Tokyo University) and Tadao Okamura (Kyoto University).

  The authors and articles included in Volume IV are as follows: Kazuhiro Takei, Taeko Morita and Hiroki Kaga contributed "Application of Tax Provisions regarding Corporate Reorganization to Cross-Border Corporate Reorganization - Proposal of Guidelines of Interpretation of ‘Group Doctrines’", Tukasa Tahara contributed "Allegations and Proof in International Tax Litigation observed in Recent Judgments of Cases where Taxpayers Prevailed" (Co-author), Takashi Yoneda contributed "Tax Withholding on Non-residents and Foreign Corporations" (Co-author) and Akihiro Hironaka contributed "Current Status and Future of the Japanese Anti-Tax Haven (CFC) Regime".

Authors

Kazuhiro Takei has extensive expertise representing Japanese public companies on a variety of matters, including M&A, corporate governance and digital transformation, corporate law, securities law, shareholders meeting, consumer law, and tax law. 

弘中 聡浩

Akihiro’s experience covers product liability, contractual claims, mass tort claims, and tax disputes, in various industries, in particular in the pharmaceutical and automotive industries. He has also handled disputes arising from M&A transactions, disputes involving construction sites in Asia, Africa, and the Middle East, and disputes arising from the termination of distribution agreements. He has achieved significant results in international arbitrations, including emergency arbitration proceedings under the rules of the ICC, SIAC, AAA-ICDR, and JCAA. He also advised clients in connection with US civil actions, including class actions, and Japanese judicial assistance for foreign court proceedings.

In one notable case, he successfully defended a Japanese trading company against six large vicarious liability lawsuits, involving claims totaling JPY 48.3 billion, filed by claimants including an affiliate of a US-headquartered investment bank and a US hedge fund. He also recovered JPY 13.3 billion for Shionogi & Co. in an action challenging a tax assessment relating to an in-kind contribution of a partnership interest in a cross-border reorganization for the development of a drug for AIDS. He is currently representing a pharmaceutical company in one of the largest product liability lawsuits in Japan.

He is a graduate of The University of Tokyo (LL.B., 1993) and Harvard Law School (LL.M., 2003), and is licensed to practice law in Japan and New York. He served as a Japanese district court judge from 1998 until 2000, and worked at Arnold & Porter (Washington, D.C.) from 2003 until 2004. He is a Fellow of the Chartered Institute of Arbitrators.

He is the author of various books and articles in the areas of litigation and international arbitration, including Yasuhei Taniguchi et al. eds., Civil Procedure in Japan (contributor, Juris Publishing). He was awarded the "Dispute Resolution Lawyer of the Year" at the ALB Japan Law Awards in 2022.

森田 多恵子

Since she joined Nishimura & Asahi in 2004, she has been involved in various types of corporate matters, including M&A, compliance and corporate group internal controls. She handles in day-to-day matters as well as strategic and special situations, and can provide business advice. With respect to corporate governance matters, she provides practical advice on the full spectrum of corporate governance matters including administration of shareholder meetings, company organization structures, disclosure, administration of the board of directors, board evaluations, executive compensation, and company indemnification. She also has extensive experience in the field of consumer law matters, such as how to respond to consumer-law related regulations, consumer organizations, and investigations by authorities. She has expertise and provides advice on advertising, marketing activities, and e-commerce.

加賀 宏樹

By leveraging his experience abroad and his secondment to a trading company in Japan, Hiroki Kaga has experience in complex cross-border transactions. His strength is the knowledge and experience of cutting-edge practices in the M&A, start-up and private equity area.

田原 吏

In M&A transactions, Tsukasa has been involved in a nubmber of transactions, including management integration of large companies, going-private transactions, business carve-outs transactions, and establishment of joint ventures. In recent years, he has especially focused on tender offer transactions, including management buy-outs, and business succession of owner-operated companies. He is strong in efficient and steady execution of transactions based on his extensive experience and is committed to providing flexible solutions that are tailored to the client's situation. In the area of general corporate matters, he handles a wide range of cases, including corporate governance, drafting and review of various contracts, and corporate disputes. He has a deep understanding and extensive experiences of the manufacturing and retail sectors, as well as finance, automotive/auto parts, logistics, and food and beverage.