Understanding the new earning-stripping rules (August 2012)

Mayuko is an attorney at Nishimura & Asahi (admitted in Japan and New York). Her practice includes corporate matters including M&A as well as international tax and tax dispute. She has experience engaging in tax treaty negotiations and domestic procedures thereof from her time as a deputy director at the Economic Treaties Division, International Legal Affairs Bureau, Ministry of Foreign Affairs of Japan from 2017 to 2019.

Tsuyoshi Ito has significant experience in tax counseling and tax controversies and has represented major corporations in numerous tax disputes and tax lawsuits. In March 2021, he won a significant corporate tax dispute that challenged a tax assessment of approximately USD 367 million in taxable income before the Tokyo High Court after a protracted seven-year battle. In August 2014, he won a tax dispute involving securitization transactions of domestic housing loans before the Tokyo High Court. In addition to excellent achievements in major tax disputes, he generally advises on domestic and cross-border taxation issues in various transactions, such as M&A, joint ventures, fund formation and equity/debt investments.