Edwin 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. He 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. He 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.
- Band 1 in Tax, Chambers Asia, 2011 - 2018
- Band 1 in International Trade, Chambers Asia, 2011 - 2016
- Leading Lawyer in Tax:Foreign, Legal 500, 2010 - 2018
- Leading global tax lawyers, Asia Pacific Legal 500, Tax Directors Handbook, Asialaw Profiles and Chambers Asia, 2012
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
- Edwin provides pro bono assistance on various matters through his membership of the California, Georgia and Tokyo Bar Associations, and takes part in charitable activities in his work with various non-profit organizations. He also devotes substantial time on a voluntary basis to the International Fiscal Association and the Tax Committee of the American Chamber of Commerce in Japan.
- Japan (Attorney at Foreign Law)~Japan (1996)
- Georgia~United States (1992)
- California~United States (1990)
- Stanford University (J.D.) (1990)
- Harvard University (A.B.) (1981)
- San Francisco
Co-author, "Japan," BNA Global Tax Guide, BNA, London, 2009 (and subsequent updates)
Co-author, "How New Treaties Will Affect Corporate Taxes in Japan," Law 360, September 2018
Co-author, "Japan's 2018 Tax Reform Proposal," Tax and Transfer Pricing Client Alert, Baker McKenzie, December 2017
"Taxation of the Digital Economy," 2018 Baker McKenzie Asia Pacific Tax Conference, Singapore, September 2018
"Asia Pacific Tax Update - Part 1," 2018 Baker McKenzie Asia Pacific Tax Conference, Singapore, September 2018