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Tax Advisers - Deloitte

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Japan<br />

Koichi Sekiya<br />

Shin Nihon Ernst & Young<br />

Hibiya Kokusai Building 20F<br />

2-2-3 Uchisaiwai-cho<br />

Chiyoda-ku, Tokyo 100-0011<br />

Japan<br />

Tel: (81) 3 3506 2447<br />

Fax: (81) 3 3506 2200<br />

Email: koichi.sekiya@jp.ey.com<br />

Website: www.sney.com<br />

Koichi Sekiya is a tax partner in Shin Nihon Ernst & Young, one of the largest tax<br />

professional firms in Japan. He is a leading partner of the firm’s transaction tax and<br />

international tax services groups. He has over 20 years of tax experience.<br />

He currently focuses on cross-border mergers and acquisitions tax advisory services for<br />

multinationals and investment funds, both inbound to Japan and outbound from Japan.<br />

He specializes in mergers and acquisitions structuring, including tax due diligence, preand<br />

post-acquisition reorganizations, tax-effective financing, basis step-up planning,<br />

debt push down and thin-capitalization planning. He also provides structuring advices<br />

for private equity and real estate investment funds.<br />

Koichi Sekiya has long and extensive experience in general international tax areas of<br />

advisory services including: corporate reorganizations (merger, corporate split, share<br />

exchange); pass-through entities and investment vehicles (NK, TK, LP, LLP, TMK,<br />

LLC); withholding tax planning on royalties and interest; dividends and cash<br />

repatriation planning; Japanese foreign tax credits; Japanese CFC rules (the tax haven<br />

rules); permanent establishment issues and commissionaire structure; and tax audit<br />

defence.<br />

Between 1993 and 1997, he served on Ernst & Young’s Japanese tax desk in New York.<br />

While in New York, he provided tax advisory services to large multinational clients in a<br />

variety of industry groups. In addition to this role, he worked jointly with international<br />

tax professionals located throughout the United States and in other foreign countries.<br />

Koichi Sekiya holds a LLB from Rikkyo University and is a licensed tax accountant<br />

(Zeirishi).<br />

128 Guide to the World’s Leading <strong>Tax</strong> <strong>Advisers</strong>

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