Hiroyuki Kurihara

Practice Areas

Tax, M&A, Corporate

Career

with Weil, Gotshal & Manges, New York (2016).

Lecturer, The University of Tokyo, School of Law (2011-2014).

Membership Officer of the LAWASIA Taxation & Customs Committee (2021-).

Professional Memberships

Admitted in Japan, 2008; New York, 2016.

Japan-Licensed Tax Accountant, 2017.

Chartered Member of the Securities Analysts Association of Japan (2016).

Publications

Report Concerning Research on Preferential Tax Systems in Asian Countries, Commissioned by the Ministry of Finance (March 2017).

Report Concerning Research on the Mandatory Disclosure Rules for Tax Planning in Foreign Countries, Commissioned by the Ministry of Finance (September 2017).

Research Report on Double Taxation Adjustment for Dividends and Taxation on Capital Gains and Losses from Transfer of Shares, a Research Project Commissioned by the Ministry of Finance (June 2021).

Work Highlights

Represented a corporate client in a tax dispute regarding the fair value of transferred business through an absorption-type company split (kyushu bunkatsu) and obtained a final court judgement in its favor, ordering the rescission in full of the tax authority’s disposition for unreported capital gains in the amount of approximately JPY 600 million (2023).

Represented the founder of Sazaby League, Ltd. and another company in a first-ever tax dispute regarding the fair value of class stock and obtained a National Tax Tribunal decision in their favor, ordering the rescission in full of the tax authority’s disposition for taxation of at least JPY 8 billion (2022).