Tax litigation regarding securitization transactions for domestic housing loans

Akihiro HironakaHisashi MiyatsukaTsuyoshi Ito
2012 - 2014
Practice Areas
Tax Disputes

Our lawyers represented a Japanese bank which challenged a 2007 tax assessment on the securitization transactions of domestic housing loans. In August 2014, the Tokyo High Court (Chief Judge Kazuo Miwa) reversed the lower court judgment which denied the taxpayers' claims, and approved all claims by the taxpayer. The government of Japan did not appeal to the Supreme Court, and the judgment approving all the taxpayers' claims has become final.

This judgment is significant for the practice of securitization transactions, and is also of theoretical importance, because the basic issue of the relationship between the tax law and accounting rules was in dispute.

Akihiro Hironaka, Hisashi Miyatsuka, Tsuyoshi Ito, Hiroshi Yagi, Hironori Kino, Mayuko Nakamura and Seisuke Imai represented the client in this case.