Current Employment Position(s)

Partner

Languages

• English
• Japanese

Lawyer Overview

Since 1984, Koichi Inoue has practiced in the field of international transactions and dispute resolutions, with primary emphasis on the international aspects of Japanese tax law. His tax experience consists primarily of two areas: providing tax-related advice to clients and representing taxpayers in difficult administrative proceedings and tax litigation.

Koichi works together with other Jones Day offices for multinational companies in a variety of industries, including pharmaceuticals, telecommunications, electrical machinery, real estate development, publishing, and retail. Jones Day's worldwide network is highly effective in covering complicated tax issues involving two or more jurisdictions when those multinational companies conduct international transactions and plan and implement restructuring of their global operations.

Koichi also deals with not only administrative proceedings and tax litigation but defense of taxpayers in tax audits. He served as the sole counsel in Iwase v. Director of Tokyo Ueno District Tax Office, et al., 1685 Hanji 33 (Tokyo High Court 1999) and achieved a complete victory. The Tokyo High Court judgment, which was affirmed by the Supreme Court of Japan in 2003, attracted widespread attention of scholars and practitioners because it directly addressed the issue of the constitutional principle of no taxation without law.

In addition to tax-related matters, Koichi provides a wide variety of legal services in the field of general corporate and dispute resolutions. In this capacity he has worked for clients that include Applied Biosystems Japan (a Japanese wholly owned subsidiary of Applera Corporation), Wipro Limited (the largest software company in the world), and Mitsubishi Cable Industries (a comprehensive electric wire and cable manufacturer).

In 2004, Koichi was appointed as a national reporter of the Foreign Lawyers Forum of the American Bar Association as a successor to Masatami Otsuka of the Firm's Tokyo Office. A jointly prepared annual report is available on the ABA Web site. Koichi regularly writes and lectures on international taxation and tax litigation. He is fluent in English and Japanese.

Areas of Practice

• Tax
• International/Cross-Border Planning & Transactions
• Mergers & Acquisitions/Tax
• Private Equity/Tax

Representative Cases

• Purchase of distributor
• Sale of Consumer Healthcare Business

West Practice Categories

Banking & Finance Law, Corporate Taxation, Estate & Gift Taxation, Excise Taxes, Income Taxation, International Law, International Taxation, International Taxation, International Transactions, Mergers, Acquisitions & Divestitures, Payroll Taxes, Property (Ad Valorem) Taxes, Sales & Use Taxes, Taxation Law

Bar Admissions

• Japan

Education

• Tokyo Daigaku - Japan

Published Works

• Interaction between Japan's Tax Treaties and Domestic Tax Law, Bulletin for International Taxation, Vol. 61, No. 9/10 - 2007, published by IBFD, 2007
• The Interrelation between Tax Treaties and Domestic Tax Law, coauthor, published by Shoji Homu, 2007
• The Interrelation between Tax Treaties and Domestic Tax Law, coauthor, Journal of the Japanese Institue of International Business Law, Vol. 30, No. 7, 2002-Vol. 32, No. 11, 2004, 2004
• Tax Aspects of Transactions with Foreign Corporations, coauthor, Shoji Homu, 1996; 2d. ed. 2000; 3rd ed. 2002, 1996

Address

Kamiyacho Prime Place
1-17, Toranomon 4-chome
Minato-ku, Tokyo 105-0001 105-0001, Japan

Phones

81.3.6800.1816 (Business Phone)

Faxes

81.3.5401.2725 (Business Fax)

Emails

Contact Us (Business Email)

Websites

http://www.jonesday.com