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Whatley

Edwin T. Whatley

Partner
Baker & McKenzie (Gaikokuho Joint Enterprise)

Biography

Edwin Whatley leads the Firm’s Tax Practice Group in Tokyo and is highly experienced in both US and Japanese tax law. He is recognized as a leader in his field by the Asia Pacific Legal 500, Tax Directors Handbook and Chambers Asia. Mr. Whatley has authored numerous articles on US and Japanese tax and regularly speaks on tax matters at international conferences and seminars. He is actively involved in pro bono work, including assistance on various matters to the California, Georgia and Tokyo Bar Association. Prior to joining the Tokyo office, Mr. Whatley worked in the Firm’s San Francisco practice.

Practice Focus

Mr. Whatley focuses on international taxation, corporate and international tax planning, transfer pricing and tax controversies for Japanese and foreign corporations. He also works with clients on reorganizations and acquisitions in Japan. Mr. Whatley advises on transfer pricing analysis and controversies, and helps Japanese multinationals on foreign tax issues. He is seasoned in unilateral and bilateral transfer pricing matters involving Japan, the US and other countries. Mr. Whatley also handles tax structuring, preparation of documentation, and Japanese tax rulings to reduce or eliminate withholding tax on transactions in software and other intangibles, as well as Japanese consumption tax and customs.

Representative Legal Matters

  • Advised IT and technology services US companies and worked closely with Japanese lawyers on the commercial, corporate, intellectual property and tax law aspects of Japanese operations.
  • Worked with a range of US and international corporate clients, including numerous high-tech companies.
  • Advised US companies and worked closely with Japanese lawyers on the commercial, corporate, intellectual property and tax law aspects of Japanese operations.
  • Prepared and reviewed distribution, licensing, OEM and joint venture agreements.
  • Acted for US clients in relation to corporate tax planning for Japanese operations and tax planning for US expatriates stationed in Japan.
  • Represented US clients in administrative proceedings and litigation in tax and intellectual property matters.
  • Represented and assisted Japanese companies with respect to their US operations involving US and multinational tax planning, US acquisitions, US tax controversies (especially transfer pricing matters) and US litigation.

Professional Associations and Memberships

  • California State Bar Association - Member
  • American Chamber of Commerce in Japan - Tax Section
  • American Chamber of Commerce in Japan - Co-Chair, Tax Committee
  • International Fiscal Association - Member
  • Georgia Bar Association - Member
  • Tokyo Bar Association - Member

Admissions

  • Japan (Attorney at Foreign Law)~Japan (1996)
  • Georgia~United States (1992)
  • California~United States (1990)

Education

  • Stanford University (J.D.) (1990)
  • Harvard University (A.B.) (1981)

Languages

  • English
  • Japanese

Previous Offices

  • San Francisco