Of Counsel

東京 + 81.3.6800.1838

Kyosuke Katahira's practice focuses on international tax advice for multinational enterprises (MNEs) based primarily in Japan and the United States. For more than 15 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 Chambers Asia-Pacific, The Legal 500 Asia Pacific, and The Best Lawyers in Japan for tax.


  • Electrolux acquires Tosei CorporationJones Day advised Electrolux Professional Group, a Swedish professional appliance manufacturing company operating globally, in connection with its acquisition of Tosei Corporation from Marunouchi Global Fund II and Marunouchi Capital Fund II, both related to Mitsubishi Corporation, for approximately SEK 1,650 million (JPY 23.25 billion) on a cash and debt free basis.
  • Sumitomo acquires assets and rights related to lefamulin from NabrivaJones Day advised Sumitomo Pharma Co., Ltd. in the acquisition of assets from Nabriva Therapeutics plc and various wholly-owned subsidiaries. This acquisition includes assets from the U.S., Ireland, and Austria in support of the development, manufacture, marketing and commercialization of lefamulin in the People’s Republic of China, Hong Kong, Macau and Taiwan.
  • Chevron and MOECO agree to explore advanced closed loop geothermal pilot in Hokkaido, JapanJones Day advised Chevron New Energies on its agreement with Mitsui Oil Exploration Co., Ltd (MOECO) to proceed with the pilot testing of advanced geothermal technology, specifically advanced closed loop (ACL) technology.
  • TotalEnergies' affiliate Cray Valley sells three product lines to Pacific Avenue Capital PartnersJones Day is advising Total Energies on its sale of three product lines to Pacific Avenue Capital Partners (Wingtack®, PolyBD® and Dymalink®) developed by Cray Valley, its resin production and sales affiliate.
  • Sempra Energy sells PXiSE Energy SolutionsJones Day advised Sempra Energy in the sale of membership interests in PXiSE Energy Solutions to Yokogawa Electric Corporation.
  • Materion acquires H.C. Starck's electronic materials portfolio for $380 millionJones Day advised Materion Corporation, a world leader in high performing advanced materials, in connection with the acquisition and financing of H.C. Starck Solutions' industry-leading, electronic materials business, located in Newton, Massachusetts ("HCS-Electronic Materials") for $380 million.
  • Riverside sells Y InternationalJones Day advised The Riverside Company in the sale of Y International, Inc., a Japanese bicycle retailer, to Daiwa PI Partners Co., Ltd.
  • ETS acquires TOEFL® assets of Council on International Educational Exchange (CIEE)-JapanJones Day advised ETS in the acquisition of the TOEFL® assets of the Council on International Educational Exchange (CIEE)-Japan.
  • Sumitovant Biopharma acquires remaining stake in Urovant SciencesJones Day advised Sumitovant Biopharma in its acquisition of all of the outstanding shares of Urovant Sciences Ltd. not already owned by Sumitovant at a price of $16.25 per share in cash.
  • GCA Altium acquires Stella EOCJones Day advised GCA Altium in the acquisition of Stella EOC, a technology and media investment banking boutique with coverage in the UK and Europe.
  • Sumitomo Heavy Industries invests $46 million into Highview PowerJones Day advised Sumitomo Heavy Industries, Ltd., a technology leader in industrial machinery and environmental and power technologies, in its $46 million investment into Highview Power, a global leader in long-duration energy storage solutions.
  • Sumitomo Heavy Industries acquires InvertekJones Day advised Sumitomo Heavy Industries, Ltd. in the acquisition of the entire issued share capital of Invertek Drives Ltd.
  • PAG Holdings sells minority interest to Blackstone Strategic Capital Holdings FundJones Day represented PAG Holdings Ltd., one of Asia’s largest independent alternative asset managers, in connection with its sale of a minority interest in PAG to the Blackstone Strategic Capital Holdings Fund.
  • Calgon Carbon acquired by Kuraray for $1.3 billionJones Day advised Calgon Carbon Corporation (NYSE:CCC) in its $1.3 billion all-cash acquisition by Kuraray Co., Ltd. (TSE:3405).
  • Norinchukin and MUFG strengthen and expand retail business allianceJones Day advised The Norinchukin Bank, the national-level financial institution for agricultural, fishery, and forestry cooperatives in Japan, in reaching an agreement with Mitsubishi UFJ Financial Group ("MUFG") on an initiative to enhance the business and capital alliance transaction including the consumer finance business.
  • GE Digital acquires IQP CorporationJones Day advised GE Digital in its acquisition of IQP Corporation, a start-up operating in Israel, Japan, and the U.S. that provides a no-code or low-code IoT app builder, with a visual interface available on mobile, tablet, and PC, includes data apps, and is installable on public cloud, private cloud, and on premise.
  • OMRON acquires SentechJones Day advised OMRON Corporation in connection with the ex-Japan aspects of its acquisition of Sentech Co., Ltd., a manufacturer of industrial cameras.
  • PAG Asia Capital sells remaining stake in Universal Studios Japan to Comcast NBCUniversalJones Day acted as lead counsel to PAG Asia Capital Ltd. in the sale of its remaining stake in Universal Studios Japan as part of the ¥254.8 billion (US$2.3 billion) sale of Universal Studios Japan to Comcast NBCUniversal, an owner and operator of world-renowned theme parks.
  • HNA EcoTech Pioneer Acquisition acquires majority stake in Advanced Card Systems Holdings LimitedJones Day advised HNA EcoTech Pioneer Acquisition, an indirect subsidiary of HNA EcoTech Group Co., Ltd., in its acquisition of a 61.39 percent stake in Advanced Card System Holdings Limited ("ACS") for HK$521.8 million (US$67.3 million) and a subsequent mandatory unconditional cash offer of HK$328.2 million (US$42.3 million) to acquire all remaining shares.
  • Altium completes merger with GCA Savvian to create leading global investment bank GCAJones Day advised Altium, a leading international mid-market financial advisory group, in a merger with GCA Savvian Corporation, a premier global investment bank listed on the Tokyo Stock Exchange, to form GCA, a leading independent international investment bank focused on growth companies with an extensive global network, cross-border capability, and track record of industry-shaping transactions.
    • March 2022
    • November 2021
      IFA (International Fiscal Association): OECD Pillar 2 - Minimum tax