Rescission of tax reassessment regarding an in-kind contribution of a partnership interest
Nishimura & Asahi, on behalf of a major Japanese pharmaceutical company, won a significant corporate tax dispute, that challenged a tax assessment before the Tokyo District Court, after a protracted, six-year battle, as lead counsel. This case involved an issue arising from an in-kind contribution of a partnership interest for the development of a drug to fight AIDS. The amount of taxable income in dispute was approximately JPY 40.5 billion (approx. USD 367 million).