Senior Foreign Attorney
Steve Minhoo KIM
Transfer Pricing
Steve Minhoo Kim is a Senior Foreign Attorney (District of Columbia) whose specialty lies in International Tax and Transfer Pricing. His early career with Big 4 accounting firms exposed him to abundant experiences across various industries and allowed him to be equipped with requisite professional knowledge and skillsets to excel in the field of international tax and transfer pricing.
His international tax and transfer pricing projects encompass TP documentation (including loan pricing and calculating financial guarantee fee), management service fee planning and documentation, tax audit defense, Advance Pricing Agreement (BAPA/UAPA), Mutual Agreement Procedure (MAP), TP planning, TP policy and internal control establishment, Statutory (tax) valuation, Merger/demerger planning and execution, Permanent Establishment risk assessment, a claim for rectification in regard to TP and other tax items, tax planning in relation to outbound investment, other general tax consulting, etc.
Steve holds a Bachelor's degree in Commerce and Finance with high distinction from Rotman School of Management at University of Toronto St. George Campus and also earned a Master's Degree in Business Administration (MBA) with high distinction from Korea Advanced Institute of Science and Technology, Known as KAIST. He has also earned his LLM degree at University of Connecticut in an effort to expand his horizon to legal perspective of tax matters. He is a member of District of Columbia Bar and also licensed CPA in Washington State.
His international tax and transfer pricing projects encompass TP documentation (including loan pricing and calculating financial guarantee fee), management service fee planning and documentation, tax audit defense, Advance Pricing Agreement (BAPA/UAPA), Mutual Agreement Procedure (MAP), TP planning, TP policy and internal control establishment, Statutory (tax) valuation, Merger/demerger planning and execution, Permanent Establishment risk assessment, a claim for rectification in regard to TP and other tax items, tax planning in relation to outbound investment, other general tax consulting, etc.
Steve holds a Bachelor's degree in Commerce and Finance with high distinction from Rotman School of Management at University of Toronto St. George Campus and also earned a Master's Degree in Business Administration (MBA) with high distinction from Korea Advanced Institute of Science and Technology, Known as KAIST. He has also earned his LLM degree at University of Connecticut in an effort to expand his horizon to legal perspective of tax matters. He is a member of District of Columbia Bar and also licensed CPA in Washington State.
主要事例
- Transfer Pricing
- Successfully defended a U.S.-based OLED materials company in a transfer pricing tax audit.
- Transfer Pricing
- Successfully defended a U.S.-based food franchise company in a transfer pricing tax audit.
- Transfer Pricing
- Successfully defended a U.S.-based life insurance company in a transfer pricing tax audit.
- Transfer Pricing
- Successfully defended a U.S.-based game development company in a transfer pricing tax audit.
- Transfer Pricing
- Provided advisory services on global transfer pricing policy development for major conglomerates across various industries in Korea.
- Transfer Pricing
- Represented a footwear manufacturer in a bilateral Advance Pricing Agreement (APA) negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.
- Transfer Pricing
- Represented a Korean trading company in a bilateral APA negotiation between the Directorate General of Taxes (DGT) of Indonesia and the National Tax Service (NTS) of Korea.
- Transfer Pricing
- Represented a Korean manufacturing company in an APA and Mutual Agreement Procedure (MAP) negotiation between the Canada Revenue Agency (CRA) and the National Tax Service (NTS) of Korea.
- Transfer Pricing
- Represented a German automobile manufacturer in a bilateral APA negotiation between the German Federal Central Tax Office (BzSt) and the National Tax Service (NTS) of Korea.
- Transfer Pricing
- Advised Korean corporations on handling overseas transfer pricing tax audits and litigation support.
- Transfer Pricing
- Prepared transfer pricing documentation, including BEPS Local File, Master File, and Country-by-Country (CbC) Reporting, for domestic and foreign-invested corporations.
- Transfer Pricing
- Provided advisory services on transfer pricing policy development related to management service fees and their deductibility for Korean and foreign-invested enterprises.
- Transfer Pricing
- Conducted transfer pricing policy assessments and prepared reports on the arm’s length pricing of guarantee fees for major Korean conglomerates.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Advised foreign-invested enterprises on domestic tax and international tax issues, including corporate income tax, individual income tax, VAT, and tax credits.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Provided advisory services on permanent establishment (PE) risks and transfer pricing issues related to the incorporation of foreign-invested entities in Korea.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Assisted foreign-invested enterprises in evaluating unlisted stock valuations under the Inheritance and Gift Tax Act and the Income Tax Act in relation to restructuring and governance changes.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Advised foreign-invested enterprises on tax implications related to corporate restructuring, including mergers and acquisitions.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Represented foreign-invested enterprises in withholding tax exemption or reduced withholding tax rate applications under tax treaties.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Prepared transfer pricing reports to determine arm’s length price in domestic related-party transactions governed by the Korean Corporate Income Tax Act.
- Other Inbound Tax Advisory (Domestic Tax Services for Foreign-Invested Companies)
- Provided advisory services and litigation support on income characterization (e.g., business income vs. royalty income) and beneficial / substantial ownership issues for foreign-invested enterprises.
- Outbound Tax Advisory (Overseas Investment Tax Services)
- Provided tax structuring advice for Korean corporations investing overseas or establishing foreign subsidiaries, including assessments of tax risks related to VAT, permanent establishments, transfer pricing, corporate tax, and withholding tax in the target jurisdiction.
- Outbound Tax Advisory (Overseas Investment Tax Services)
- Advised domestic investment funds on tax implications related to overseas real estate investments.
- Outbound Tax Advisory (Overseas Investment Tax Services)
- Assisted Korean corporations in managing and responding to tax litigation in foreign jurisdictions.
学歴
| 2019 | University of Connecticut - LL.M. |
|---|---|
| 2011 | KAIST Graduate School of Management - MBA |
| 2008 | University of Toronto, Rotman School of Management, B.Com |
経歴
| 2018-Present | Lee & Ko |
|---|---|
| 2015-2018 | Shin & Kim |
| 2011-2015 | Deloitte Anjin LLC |
| 2011 | Ernst & Young Korea |
| 2008-2009 | HSBC Canada |
資格/会員
| 2020 | Admitted to bar, District of Columbia |
|---|---|
| 2015 | Washington State, CPA |
| 2015 | U.S. Enrolled Agent admitted to practice before IRS |
言語
| Korean and English |
受賞実績
| 2023 | International Tax Review (ITR) Asia-Pacific Transfer Pricing Leader of the Year (Shortlisted) |
|---|---|
| 2022 | International Tax Review (ITR) Asia-Pacific Rising Stars Awards Winner – Transfer Pricing |
著書/活動
- Chambers and Partners 2021 Transfer Pricing Guide, Korean Chapter, April 9, 2021
- IFA Korea Tax Webinar, Session 4 (Impact of COVID-19 on Transfer Pricing) Panelist
- South Korea - Trend in Transfer Pricing, November 16, 2020, Bloomberg Tax
- South Korea - Trend in Permanent Establishment, October 21, 2020, Bloomberg Tax
- New South Korea Transfer Pricing and Diverted Profit Tax Laws enter into Effect, April 16, 2020, MNE Tax
- Korean Tax Law Adopts New Simplified Transfer Pricing Rules relating to Low Value-adding Intra-group Services, January 20, The Legal 500
- Korean Chapter of Transfer Pricing Documentation Standards 2018, PKF International
- Korean Chapter of PKF Asia Pacific Tax Guide 2017/18, PKF International
- Korean Chapter of PKF Worldwide Transfer Pricing Guide 2017/18, PKF International
- Korean Chapter of OECD BEPS ACTION PLAN STATUS UPDATE REPORT DECEMBER 2017, PKF International
