• Advised a leading global information, communication, and technology company on permanent establishment and VAT issues arising from operations in Korea. 
• Advised a major Korean machinery manufacturer on US permanent establishment and withholding tax issues related to periodic presence of employees in the US. 
• Collaborated with Ireland and Luxembourg law firms in advising a Korean venture capital firm on Ireland and Luxembourg tax implications for investment in Irish corporation via a Luxembourg SPC. 
• Advised a Korean subsidiary of a leading multinational auto parts manufacturer on application of treaty benefits under the Korea-Luxembourg Tax Treaty to royalties paid by the Korean subsidiary to its foreign affiliate. 
• Advised a multinational tools manufacturer on Korean tax considerations for internal restructuring. 
• Advised a leading global stock photography company on general Korean tax implications of establishment of a Korean subsidiary and Korean tax considerations for buy-sell model. 
• Advised a leading multinational computer technology corporation on income classification of fees paid by a Korean subsidiary to its foreign affiliate. 
• Advised a global leading private equity fund on tax litigations involving permanent establishment and beneficial ownership issues. 
• Advised multinational technology companies on tax audits involving income classification (business profits vs. royalties) and permanent establishment issues. 
• Advised high-net-worth US citizens/green-card holders on compliance with US tax laws, including filing of Streamlined Foreign Offshore Procedures package. 

Publications/Activities

• Country Report for Republic of Korea, Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructuring (Peter H. Blessing ed.) (Co-author, Kluwer Law International, 2017)