PROFESSIONALS

Nobuaki IWASHINA


Practice Area


Education

Northwestern University School of Law (LL.M., 2005)
Legal Training and Research Institute of the Supreme Court of Japan (1999-2000)
The University of Tokyo (LL.B., 1997)

Admission

Japan (2000)
Certified Public Tax Accountant (2010)

Experience

Advisor for the International Tax Affairs Task Force of the Japan Association for Chief Financial Officers (2015-Present)
TMI Associates (Associate, 2006-2007, 2009-2012; Partner, 2013-Present)
Lecturer at Tsukuba University Graduate School of Business Sciences (2015-2017)
Member of the Study Group on Taxation for Foreign Business Entities of the Ministry of Economy, Trade and Industry (2011-2012)
National Tax Agency (2007-2009)
Abe & Matsutome Law Office (2002-2006)
Greenberg Traurig LLP (2005)
Ushijima & Partners Law Office (2000-2002)

Languages

Japanese / English

Memberships

Daini Tokyo Bar Association
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Articles & Publications

2018/12/25ARTICLE “Outlook for Corporate Legal Practice in 2019 by Topic: ‘Tax Affairs’ – Please Pay Attention to the Response to the Consumption Tax Hike and the Revisions of International Tax Systems”
2018/12/01ARTICLE “Intellectual Property Rights and Tax Issues (Vol. 3) Calculation of Royalty Rate and Consideration for Assigning Intellectual Property; Transfer Pricing Taxation and Taxation on Donations”
2018/11/01ARTICLE “Intellectual Property Rights and Tax Issues (Vol. 2) License Agreements and the Impact of Withholding and Tax Treaties”
2018/02/21ARTICLE “Training for Legal Department Staff on Stamp Duties”
2018/01/21ARTICLE “Tax Knowledge for Legal Department Staff (Final): Tax Litigation”

Seminars & Lectures

2018/03/05EXTERNAL “Tax Issues in Intellectual Property Transactions – Incentives for Inventions, License Agreements and Withholding Tax and Tax Treaties, Transfer Pricing Taxation, Etc.”
2017/07/25EXTERNAL “New CFC Rules: Consideration of Cases and Panel Discussion Regarding a System Where Tax Is Imposed on the Entirety of the Company and on Passive Income”
2016/08/24EXTERNAL “’ONESOURCE Day – Synergy Between International Tax Affairs and Technologies’ The Latest Trends in International Tax Affairs and Trade Management and Leading Technologies”
2016/07/22EXTERNAL “Report on an Investigation Entrusted by the Ministry of Economy, Trade and Industry: Investigation on Trends in Various Countries and Responses Made by Japanese Enterprises Based on the BEPS: ‘Trends in Other Countries and Responses Made by Japanese Enterprises (Session 2 of 2)”
2016/07/12EXTERNAL “Report on an Investigation Entrusted by the Ministry of Economy, Trade and Industry: Investigation on Trends in Various Countries and Responses Made by Japanese Enterprises Based on the BEPS: ‘An Overview of the Final Report on the BEPS’ (Session 1 of 2)”
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Articles & Publications

2018/12/25 ARTICLE “Outlook for Corporate Legal Practice in 2019 by Topic: ‘Tax Affairs’ – Please Pay Attention to the Response to the Consumption Tax Hike and the Revisions of International Tax Systems”
2018/12/01 ARTICLE “Intellectual Property Rights and Tax Issues (Vol. 3) Calculation of Royalty Rate and Consideration for Assigning Intellectual Property; Transfer Pricing Taxation and Taxation on Donations”
2018/11/01 ARTICLE “Intellectual Property Rights and Tax Issues (Vol. 2) License Agreements and the Impact of Withholding and Tax Treaties”
2018/02/21 ARTICLE “Training for Legal Department Staff on Stamp Duties”
2018/01/21 ARTICLE “Tax Knowledge for Legal Department Staff (Final): Tax Litigation”
2018/01/08 ARTICLE “[Commentary on Legal Precedents] The Case Focusing on Status as a Non-resident with Regard to Withholding Liability for Payment of Consideration for Real Estate Assignment (Tokyo District Court Decision on May 19, 2016; Tokyo High Court Decision on December 1, 2016)”
2018/01/01 ARTICLE “[Tax Judgment Flash Report] ‘Shares of Non-traded Shares Obtained by Shareholders, Etc. Other than Family Shareholders’ (Dividend Discount Method)”
2018/01/01 ARTICLE “[New Year Special Feature] Outlook for Corporate Legal Practice in 2018 by Topic: ‘Tax Affairs’ – Increasing Tax Filing Rejection Associated with Corporate Reorganization and Responses Thereto in Professional Practice”
2017/12/21 ARTICLE “Tax Knowledge for Legal Department Staff (Vol. 8): Tax Investigations”
2017/11/21 ARTICLE “Tax Knowledge for Legal Department Staff (Vol.7): Tax Issues Occurring in Corporate Reorganization and M&A”
2017/10/21 ARTICLE “Tax Knowledge for Legal Department Staff (Vol. 6): Tax Issues Occurring in Intellectual Property Transactions”
2017/09/21 ARTICLE “Tax Knowledge for Legal Department Staff (Vol. 5): Tax Issues Occurring in the Preparation of Agreements and Consideration of Business Relationships (4) – Stamp Duties”
2017/08/21 ARTICLE “Tax Knowledge for Legal Department Staff (Vol.4): Tax Issues Occurring in the Preparation of Agreements and Consideration of Business Relationships (3)”
2017/06/23 ARTICLE “Tax Knowledge for Legal Department Staff (Vol.2): Tax Issues Occurring in the Preparation of Agreements and Consideration of Business Relationships (2)”
2017/06/30 BOOK “Lecture on Modern Tax Laws Vol.3: Corporations and Markets”
2017/04/24 ARTICLE “Tax Knowledge for Legal Department Staff (Vol.1): The Basic Concepts of Tax Matters”
2016/12/20 ARTICLE “Feature 2: Important Information! ‘Tax Affairs’ for Legal Departments – The Basics of Tax Affairs and How Legal Departments Deal Therewith”
2016/10/10 ARTICLE “Report on Research Entrusted by the Ministry of Economy, Trade and Industry: Research on Various Countries’ Trends and Japanese Enterprises’ Responses Thereto Based on BEPS (Vol.1 & Vol.2) Vol. 1: Overview of the Final Report on BEPS”
2016/06/30 ARTICLE “II Substantive Tax Law – (7) Consumption Tax: Refusal to Submit Books and Tax Deductions for Taxable Purchase”
2016/05/02 ARTICLE “[Special Program] Points to Note in Tax Affairs for Shareholders Meetings in June 2016 – Anticipated Questions and Planned Answers for Shareholders Meetings Targeting Accounting Staff and CFOs 2016”
2016/04/13 ARTICLE “Research on Various Countries’ Trends and Japanese Enterprises’ Responses Thereto Based on BEPS (Fiscal Year 2015)”
2015/01/10 ARTICLE “When Profits, Donations, Amount of Deemed Dividend, Etc. Become Points of Issue – Outline of the Decision in the Nissan Motor Case and Suggestions for Professional Practice”
2016/01/01 ARTICLE “Special Feature: Issues which Top Corporate Executives Should Overcome in the Future ‘Reinforcement of Tax Compliance Required for Corporations’”
2015/12/25 ARTICLE “Roles which Legal Departments Should Play in Tax Compliance”
2015/11/16 ARTICLE “The Effect of the ‘My Number’ System on the Implementation of Tax Practice”
2015/10/25 ARTICLE “Practical Explanations of the Latest M&A Precedents Vol. 20/Final: The Case in which Corporate Tax was Imposed by Applying the Anti-Avoidance Rule Concerning Organization Restructuring (The Yahoo Case)”
2015/10/19 ARTICLE “Vol. 57 The Case of Losing Betting Tickets as Expenses”
2015/09/01 BOOK “Legal Work Handbook for Corporate Officers <2nd Edition>”
2015/06/26 BOOK “Preparations for and How to Respond to the ‘My Number’ System”
2015/04/01 ARTICLE “CFC Rules – Necessity of Investigating the Taxation Systems of Overseas Markets’ and Careful Consideration of Whether It Is Applicable or Not”
ARTICLE “Points to Keep in Mind regarding the Act Concerning Special Measures for Passing-on of Consumption Tax – In Order not to Receive any Guidance or Recommendations for Refusing Pass-ons”
2014/12/04 ARTICLE “Court Judgments and Determinations as well as the Taxation Logic Concerning International Tax Practice; Judgment Standards of Resident and Non-resident”
2014/12/01 ARTICLE “Points to Keep in Mind Regarding Restrictions Imposed upon Licensed Professionals in Providing Advice in the Field of Inheritance”
2014/11/26 ARTICLE “[Early Spring Project] 2014 in Review; 10 Important Court Precedents for Business”
20214/06/19 ARTICLE “Cross-border outsourcing – issues, strategies and solutions”
2014/05/21 ARTICLE “Explanation on Yahoo Tax Lawsuit and District Court Decision Which Denied Succession of Loss Carried Forward”
December 25, 2013 ARTICLE “Effects of Increase in Consumption Tax and Recent Movements of Tax Authorities”
2014/01/21 ARTICLE “‘Insights of Tax Practices Lectured by an Attorney and a Tax Accountant’ (Vol. 12):  Effects of Increase in Consumption Tax Rate on Corporations (2)”
2014/01/21 ARTICLE “‘Insights of Tax Practices Lectured by an Attorney and a Tax Accountant’ (Vol. 11):  Effects of Increase in Consumption Tax Rate on Corporations”
2013/12/21 ARTICLE “‘Insights of Tax Practices Lectured by an Attorney and a Tax Accountant’ (Vol. 10):  Overseas Transfer of Manufacturing Sector – Transfer Pricing Taxation (Vol. 2)”
2013/09/23 ARTICLE “Effects on Contracts due to Increase in Consumption Tax”
2013/11/21 ARTICLE “‘Insights of Tax Practices Lectured by an Attorney and a Tax Accountant’ (Vol. 9):  Price Setting in Transactions among Affiliated Persons – Transfer Pricing Taxation (Vol. 1)”
2013/07/21 ARTICLE “‘Insights of Tax Practices Lectured by an Attorney and a Tax Accountant’ (Vol. 8):  Issues of Compliance Discovered by Tax Inspections”
2013/06/03 ARTICLE “‘Compass of Foreign Entity Taxation’ Issues on Corporate Qualification and Practical Measures (Vol. 8)”
ARTICLE [ARTICLE] Attorney Nobuaki Iwashina’s article entitled “‘Compass of Foreign Entity Taxation’ Study on Corporate Qualification of Special LPS in Cayman Islands (Vol. 7)” was published in the May 2013 issue of Zeimu Koho.
ARTICLE [ARTICLE] An article Attorney Nobuaki Iwashina participated in authoring entitled “‘Insights of Tax Practices Lectured by Attorney and Tax Accountant’ (Vol. 4):  The Year 2013 Revision of Taxation System” was published in the May 21, 2013 issue of BUSINESS LAW JOURNAL.
ARTICLE [ARTICLE] An article written by Attorney Nobuaki Iwashina and Attorney Tae Ogita entitled “‘Compass of Foreign Entity Taxation’ Study on Corporate Qualification of Foreign Entities in State of Delaware (Vol. 6)” was published in the April 1, 2013 issue of Zeimu Koho.
ARTICLE [ARTICLE] An article Attorney Nobuaki Iwashina participated in authoring entitled “‘Insights of Tax Practices Lectured by Attorney and Tax Accountant’ (Vol. 3):  Tax Depreciation When Debt-Collecting Efforts Fail (2); Risk of Avoidance” was published in the April 21, 2013 issue of BUSINESS LAW JOURNAL.
ARTICLE An article written by Attorney Hikaru Kaieda and Attorney Nobuaki Iwashina entitled “‘Compass of Foreign Entity Taxation’ Study on Corporate Qualification of Foreign Entities in Germany and India (Vol. 5)” was published in the February 2013 issue of Zeimu Koho.
2011/07/31 BOOK “Legal Consultation for Companies Regarding the Earthquake Disaster and Recovery from the Disaster -Based on the Experiences of the Great East Japan Earthquake-”
ARTICLE An article by Attorney Nobuaki Iwashina was published in the Kaisha Houmu A2Z.
ARTICLE An article by Attorney Naoki Koizumi was published in the Kaisha Homu A2Z.
ARTICLE An article by Attorney Nobuaki Iwashina was published in the Kaisha Houmu A2Z.
ARTICLE Attorney Nobuaki Iwashina’s article was published in the MARR.
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Seminars & Lectures

2018/03/05EXTERNAL “Tax Issues in Intellectual Property Transactions – Incentives for Inventions, License Agreements and Withholding Tax and Tax Treaties, Transfer Pricing Taxation, Etc.”
2017/07/25EXTERNAL “New CFC Rules: Consideration of Cases and Panel Discussion Regarding a System Where Tax Is Imposed on the Entirety of the Company and on Passive Income”
2016/08/24EXTERNAL “’ONESOURCE Day – Synergy Between International Tax Affairs and Technologies’ The Latest Trends in International Tax Affairs and Trade Management and Leading Technologies”
2016/07/22EXTERNAL “Report on an Investigation Entrusted by the Ministry of Economy, Trade and Industry: Investigation on Trends in Various Countries and Responses Made by Japanese Enterprises Based on the BEPS: ‘Trends in Other Countries and Responses Made by Japanese Enterprises (Session 2 of 2)”
2016/07/12EXTERNAL “Report on an Investigation Entrusted by the Ministry of Economy, Trade and Industry: Investigation on Trends in Various Countries and Responses Made by Japanese Enterprises Based on the BEPS: ‘An Overview of the Final Report on the BEPS’ (Session 1 of 2)”
2016/06/01Hosted / Co-hosted TMI Associates’ Special Seminar on International Tax Affairs: “Documentation of Transfer Pricing and Responses Which Japanese Enterprises Should Take Based on the BEPS”
2016/04/27MONTHLY “The Essential Basic Tax Knowledge Required by Legal Staff”
2014/12/03EXTERNAL “Effective Measures to Address Tax Investigation for Companies”
2014/07/18EXTERNAL “The Most Recent Risks in Organizational Restructuring and M&As – The Effects of 18.6 Billion Yen in Back Taxes in ‘Incident Y’ and the Latest Measures”
2014/01/17EXTERNAL “Basic Knowledge in International Tax Practice Required for Legal Department Staff”
2013/12/09Hosted / Co-hosted TMI Special Seminar “Practical Measures to Be Taken by Persons in Charge of Legal and Tax Affairs for Increase in Consumption Tax”
2013/12/04MONTHLY TMI Associates’ 65th Monthly Seminar “Practical Measures to Be Taken by Persons in Charge of Legal and Tax Affairs for Increase in Consumption Tax”
2013/10/24EXTERNAL “Specific Examples of Practical Issues to be Faced by the Increase in Consumption Tax – Shift in Increased Tax, Price Indications for Increased Tax, Effects on Contracts (Interpretation of Existing Contracts etc., Measures on Contracts etc. to be Drafted)”
2010/12/06EXTERNAL Attorney Nobuaki Iwashina gave a seminar on December 14.
2010/11/19EXTERNAL Attorney Nobuaki Iwashina gave a seminar on December 2, 2010.
2010/04/27EXTERNAL Attorney Nobuaki Iwashina will be giving a seminar on May 11, 2010.
2010/03/29EXTERNAL Attorney Nobuaki Iwashina gave a seminar on April 9, 2010.
2010/03/05EXTERNAL Attorney Nobuaki Iwashina will be giving a seminar on March 16, 2010.
2010/01/12EXTERNAL Attorney Nobuaki Iwashina will be giving a seminar on January 19, 2010.
2009/08/28EXTERNAL Attorney Nobuaki Iwashina will be giving a seminar on September 11, 2009.