Kyosuke Katahira's practice focuses on international tax advice for multinational enterprises (MNEs) based primarily in Japan and the United States. For more than 10 years, Kyosuke has attained extensive experience in different types of cross-border transactions, including M&A, joint ventures, and distribution and licensing agreements.
Kyosuke provides counsel on a wide variety of tax issues arising from both outbound and inbound transactions. In the context of inbound transactions, he advises U.S. or other foreign clients on domestic tax issues in connection with business establishment or restructuring in Japan, as well as various treaty issues arising from cross-border transactions. He also advises Japanese corporations in outbound transactions in terms of Japanese CFC (controlled foreign company) rules and corporate reorganization taxation. Kyosuke's experience extends to representation of clients in tax administrative proceedings and preparing position papers on complicated tax issues.
He also has experience in U.S. tax matters having worked in the Firm's Washington and New York offices, where he acquired deep knowledge in such areas as corporate inversion, reporting under FATCA (Foreign Account Tax Compliance Act) and FBAR (Foreign Bank and Financial Accounts), foreign tax credit "splitter" arrangements, and tax exemption under section 501(c) of the Internal Revenue Code.
In addition to advising on tax issues, Kyosuke provides counsel on corporate legal matters, including cross-border M&A transactions (both inbound and outbound), joint ventures, real estate transactions, and distribution contracts. He also has experience conducting investigations into alleged fraud.
Recently Kyosuke advised an offshore PE fund on the sale of its interest in a Japanese enterprise company.
Kyosuke is named in The Best Lawyers in Japan for tax.
- November 2021
IFA (International Fiscal Association): OECD Pillar 2 - Minimum tax
- New York University (LL.M. in International Taxation 2014; Recipient, Flora S. and Jacob Newman Award); The Legal Training and Research Institute of the Supreme Court of Japan (2007); University of Tokyo (LL.M. 2004; LL.B. 2002)
- New York and Japan (Dai-Ichi Tokyo Bar Association)
- Named in The Best Lawyers in Japan for tax
- Japanese, English