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About U.S. Export Regulations – Part I: Overview of U.S. Export Regulations (Japanese Text Only)

April 7, 2023

昨今、経済安全保障問題について活発に報道されるようになり、「輸出規制」という言葉が身近に聞かれるようになりました。輸出規則というと、日系企業にとっては、日本から海外に製品を輸出する際に、日本（自国）の輸出規則の対象となり、あくまでも自国だけの規制と思わている方も多いのではないかと思います。しかし、米国の輸出規則には、「再輸出規則」と呼ばれる制度があり、たとえ日本で製造した製品でも、米国産の製品・部品、ソフトウェア、技術が一定以上含まれている場合や、米国産の技術を使用して製造した製品である場合は、他国へ輸出する際に米国政府の許可が必要になることがあります。このような場合、無許可で製品を輸出してしまい、米国の輸出規則に違反してしまうと、禁固刑や米国製品、技術についての取引が禁止になるといった厳しい罰則があります。日本で製造活動を行っている企業でも、米国産の製品、技術、ソフトウェアを取扱っており、中国、ロシアを含む、米国が規制している国々と取引を行っている場合は、米国の輸出規制に注意する必要があります。

Key Takeaways from the 2022 Amendments to Japan’s Transfer Pricing Administrative Guidelines: Loans and Debt Guarantees (Part 1 of 2)

February 7, 2023

In June 2022, the National Tax Administration Agency (NTA) announced amendments to the Transfer Pricing Administration Guidelines. The amendments are thought to reflect the January 2022 update to the OECD Transfer Pricing Guidelines on financial transactions, and they revise Japan’s legislation on the treatment of financial transactions and cost contribution agreements (CCA). It should be noted that this may affect Japanese companies operating outside of Japan, including those operating in the United States.

HLS Global and AGS Consulting Establish Joint Venture

December 14, 2022

A partnership created to empower Japanese companies to expand globally Torrance, CA, U.S.A. / Tokyo, Japan: On December 6, 2022, Hotta Liesenberg Saito LLP (HLS) and AGS Consulting Co., Ltd. (AGS) announced the establishment of a joint venture to provide a wide range of support services to Japanese companies expanding globally. In announcing this significant partnership, the two companies are sharing their vision, spirit, and resources while fully committed to the growth and success of all our clients.

One Point Advice on Transfer Pricing Taxation

April 19, 2022

Transfer pricing is a taxation to set appropriate prices for cross-border transactions with foreign related parties based on the “arm’s-length principle” and to require appropriate tax payment in each country. For example, a transaction in which a U.S. subsidiary purchases a product developed and manufactured by a Japanese parent company and sells it in the U.S. market occurs between related parties. Because of this, the price for this transaction can be arbitrarily determined. In this case, if the sales price from the Japanese parent company to the U.S. subsidiary is too low, the income attributable to this transaction will be transferred from the Japanese parent company to the U.S. subsidiary, resulting in an understatement of taxable income reported in Japan and, conversely, an overstatement of taxable income reported in the United States. Since the income reported in Japan will be understated, if this problem is pointed out during a tax audit, the Japanese Tax Authority will reassess the income based on the correct price and impose additional tax payments, resulting in a double taxation.

COVID-19 Relief Bill – An Update Focused on PPP and ERC

March 25, 2021

Introduction The COVID-19 relief bill being debated since July in Congress was finally signed into law on December 27, 2020, as part of a broader Consolidated Appropriations Act, 2021. The new relief package ($900 billion) is intended to extend and modify certain provisions in the CARES Act ($2.2 trillion) enacted in March 2020. Together with the provisions in the CARES Act, this relief package is the largest provided by the US government in its history (e.g., the fiscal stimulus for the 2008 financial crisis was $700 billion) and is aimed largely at assisting US businesses and workers still suffering from the COVID-19 led economic hardship. The relief package is expected to stimulate the US economy during the first half of 2021.

Year-End Tax Planning Under A Biden Presidency

March 25, 2021

November 20, 2020 Although vote counting continues and legal challenges to the election endure, many news media organizations are projecting that former Vice President Joe Biden will become the 46th President of the United States on January 20, 2021. The House of Representatives will remain under Democratic control, but control of the Senate is somewhat less certain since the balance of power will be determined in January 2021 following a run-off election for two open Senate seats in Georgia. The run-off is necessary because neither of the candidates in either of the races obtained more than 50% of the total vote count as required by the state’s election law. A win by the two Democratic candidates would shift the balance of power in the Senate from one of GOP control to one where neither party has a majority. In that case, if all Senators vote along party lines (including independent senators who typically vote with Democrats), any deadlock on legislation would be broken by Vice President-elect Harris casting the deciding vote. This tiebreaking potential would also determine the Senate leadership, the ratio of committee memberships between the parties, and the leadership of each committee.

HLS US state taxes practical guide

U.S. State Taxes – A Practical Guide for Businesses Entering the United States

March 24, 2021

Companies from around the world sell their products and services into the U.S. market, either directly or through a US subsidiary. These businesses are continually looking for better ways to understand the tax and overall business climate. Many companies investing in the US need to better understand Federal as well as state income taxes. Each state is able to apply its own different tax rules and regulation to businesses that have a taxable presence within their jurisdiction. This article will highlight the differences between federal and state taxes in the United States.

HLS Global Group and HWS GmbH & Co. KG Form International Strategic Joint Venture

July 30, 2020

September 30, 2021 HLS Global HWS GmbH & Co. KG HLS HWS Europe GmbH   HLS Global Announces the Establishment of Japan Desk at the Stuttgart Office Creating New Opportunities for Japanese Companies in Europe through a Partnership Founded on Trust   Los Angeles, CA, U.S.A. / Stuttgart, Germany: As of September 1, 2021, the HLS Global group announced the opening of its new branch in Stuttgart, Germany, to start the provision of various support services to the local subsidiaries of Japanese companies in Europe.  After starting in the U.S. 30 years ago, and establishing offices in Japan, Mexico and India, this newest branch enhances HLS Global’s international expansion to Europe.  As announced on July 30, 2020, HLS Global has formed a strategic joint venture with HWS GmbH & Co. KG (“HWS”), and the firms will collaborate together  to jointly provide a variety of services in Europe. HWS is an consulting and accounting firm with a rich history of nearly 100 years and approximately 550 employees in the Stuttgart area.  Through this collaboration, the firms will integrate HLS Global’s knowhow accumulated through services provisioned to Japanese companies globally, into the proficiency developed by HWS to provide superior quality services to

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