Partner
孫秉鋑
Tax Litigation
主要业务方向
Recently reviewed Professionals
Mr. Byeong-Jun Son a tax law expert with eight years of experience as a judge for multiple courts. He has served as Senior Judge for the Daejeon District Court, a Research Judge (Taxation) for the Supreme Court, a Judge in the Seoul Administrative Court as well as the Seoul High and Seoul Central District Courts. Since Mr. Son's joining of the Tax & Customs Group in 2012, he has handled various disputes and litigations related to Customs and International Taxation and Tax Investigation, as well as providing general tax consulting and tax audits. Mr. Son currently serves as the lead partner of the Tax & Customs Group. Mr. Son is fluent in Korean, Japanese and English.
主要业绩
- Corporate tax issues for Korean Veterans Association
- Gift tax issues for Hite Jinro, Taekowng and SPP Group
- Gift tax issues for Redcap
- VAT relating to mileages for Lotte Shopping, LG Household & Healthcare, CJ Group, Pulmuone and Youngone Corporation
- VAT relating to food services at funeral homes
- Corporate tax issues relating to goodwill for Dongbu Hitek
- Corporate tax issues relating to guarantee fees for foreign subsidiary of LG Electronics
- Corporate tax issues relating to non-performing loan disposal fund bond for bankers association of Korea
- Corporate tax issues relating to subordinate bond for new airport highway, the third Gyeongin Highway and Manwolsan Tunnel
- Corporate tax issues relating to performance of guarantee debt for Hite Jinro
- Reduction of transfer income tax for newly constructed houses
- Interest income tax withholding issues for lump sum payroll
- Property tax issues regarding proper business purpose for welfare foundation
- Property tax relating to annual payments for Seoul Light Tower
- Tax Evasion case for CJ Group
- Tax Audit advisory services for Samsung, Hyundai Automobiles, SK, LG, Lotte, Hyundai Heavy Industries, Hanjin, CJ, Kolon, Halla, Hite Jinro, iljin and Korea Development Bank, etc.
- Tax Audit advisory services for CJ E&M and Korea Airport
语言
| Korean, Japanese and English |
获奖经历
| 2021 | Chambers Asia Pacific 2021 Ranked Lawyers-Tax |
|---|---|
| 2020 | Legal 500 2021 Leading individuals-Tax |
| 2014 | Prime Minister's Commendation |
著作/发表
- 'Study on Rejection of Unfair Act and Calculation', (Master thesis)
- Author, “With regard to paid-in capital increase by allotment to the third party, whether or not it is possible to consider the resolution date of the board of directors on the capital increase as a fixed date in calculating ‘appraised price per share prior to the capital increase’ under Paragraph 1(1)c of Article 39 of the previous Inheritance Tax and Gift Tax Act and Paragraph 3(1) of Article 29 of the same Act”
- Author, “Whether or not a semi-commission agent is subject to “the Supplied” under Paragraph 1 of Article 17-1 of the previous Value Added Tax Act and a consigner’s credit against the semi-commission agent is subject to bad debts tax credits”
- Author, “The range of newly built housing subject to exemption from transfer income tax stipulated by Paragraph 1(1) of Article 99-3 of the previous Restriction of Special Taxation Act and the meaning of date of acquisition”
- Author, “The subject of judgment in a complaint in the case of increased correction disposition after enforcement of Article 22-2 of Framework Act on National Taxes and the range of reason of illegality that could be claimed in such complaint”
- Author, 'The applicability of the principle of good faith to person with liability to taxation'
- Author, “The legality of estimation method to seek the standard of assessment by adding profit on exchange and gain on foreign currency translation to the estimated income sought by multiplying the standard earning rate to business income”
- Author, “Whether or not a final ruling revoking the disposition of imposition for reason of illegality of imputed time of loss is subject to later occurring reason for correctional claim under Paragraph 2 of Article 45-2 of the Framework Act on National Taxes”
- Author, “Requirement and scope of the interest resulting from exercising stock option based on issuing required stock to subject to lower tax under Article 15 of the Tax Reduction and Exemption Control Act.”
- Author, 'Period of payment of income tax resulting from disposition of income and extension period of imposing such tax.'
- Author, 'Dismissal and extension period of the Article 26, Section 2 of the Basic Law for National Taxes.'
- Author, 'Calculation of transfer income tax regarding rejection of unfair act and calculation.'
- Author, 'Scope of rejection of unfair act and calculation with respect to special party under the tax law.'
- Author, 'Whether application of inheritance tax and Article 66 of the donation tax for the purpose of inspection of donated party is valid.'
- Author, 'Problems with the disposal of re-plotting for the purpose of acquisitive prescription.'
