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| Ed focuses his practice in the areas of international taxation, transfer pricing, corporate and international tax planning, and tax controversies. |
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Ed's practice includes comprehensive tax planning for Japanese operations of foreign-based multinationals; tax planning for foreign operations and advice on specific foreign tax issues for Japanese multinationals; transfer pricing analysis and controversies; representing Japanese and foreign companies in unilateral and bilateral transfer pricing matters involving Japan, the United States (US) and other countries; tax planning, opinions and due diligence for reorganizations and acquisitions in Japan; tax structuring, preparation of documentation, and Japanese tax rulings to reduce or eliminate withholding tax on transactions in software and other intangibles; and Japanese consumption tax (VAT), all in collaboration with Japanese lawyers.
Ed has practiced tax law since 1990, first in the San Francisco Office and subsequently in the Tokyo. He is the head partner in the Tokyo Tax Group. |
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Representation of clients in tax matters is not public record and is usually confidential. Ed works with a range of US and international corporate clients including numerous high-tech companies. He works closely with Japanese lawyers in advising US companies on commercial, corporate, intellectual property and tax law aspects of Japanese operations. The following list highlights some of his work with US clients:
- Establishment and structuring of Japanese operations.
- Preparation and review of distribution, licensing, OEM, and joint venture agreements.
- Corporate tax planning for Japanese operations.
- Tax planning for US expatriates stationed in Japan.
- Administrative proceedings and litigation in tax and intellectual property matters.
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Ed's experience in assisting Japanese companies with their US operations includes the following activities:
- US and multinational tax planning.
- US acquisitions.
- US tax controversies, especially transfer pricing matters.
- US litigation.
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| Ed is regularly invited to present at tax and related seminars throughout the United States and Asia Pacific. He has written extensively on transfer pricing and taxation, including publications in the Indiana Law Journal, Taxation and E-Commerce, the World Money Laundering Review, and the Asia-Pacific Tax Bulletin. |
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| He is a member of the California, Georgia and Tokyo Bar Associations, and the Tax Committee of the American Chamber of Commerce in Japan. |
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Ed received an A.B. in History and East Asian Studies from Harvard University in 1981. He held several Japan-related positions, including work on a Tokyo magazine and research positions with the Harvard Program on U.S.-Japan Relations and the Japan Research Institute in Tokyo, before attending law school at Stanford University, from which he received a J.D. in 1990.
Ed was admitted to practice in California in 1990, in Georgia in 1992, and as a Registered Foreign Lawyer (Gaikokuho Jimu Bengoshi) in Japan in 1996. |
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