심윤상 - Kim & Chang | 김·장 법률사무소

김·장 법률사무소 (2003-현재)

Deloitte & Touche LLP, Chicago (2001-2003)

U.S. Department of Defense, Office of the Inspector General, Washington D.C. (1994-1998)

Tax Audit and Dispute Resolution

Represented a major global oil company in tax audit and administrative appeals thereafter on the beneficial ownership of dividends.
Represented a major US private equity fund in tax audit on beneficial ownership and permanent establishment issues related to Korean source capital gains income.
Advised a US technology company in successfully concluding mutual agreement procedure between US and Korean competent authorities.
Represented a major international consulting firm in tax audit and administrative appeals thereafter on deductibility of management service fee and royalty rate transfer pricing.
Represented a major US software company in tax audit, administrative appeals and court proceeding on deductibility of management service fee and beneficial ownership of royalty income.
Advised a major sovereign fund on the litigation of tax assessment related to thin capitalization treatment of related party loan.
Represented a major US multilevel marketer in administrative appeal and court on the deductibility of management service fee and royalty rate transfer pricing.
Represented a global pharmaceutical company in tax audit which various issues but primarily focused on transfer pricing and entertainment expense issues.

Tax Consulting

Advised a major US private equity fund in tax efficient structuring of investment in Korean company.
Assisted a European technology company in obtaining High Tech Technology designation for tax holiday benefits.
Represented a major German automotive components company in determining the valuation of shares transferred for the purposes of calculating the securities transaction tax.
Provided a global cosmetics company a comprehensive assessment of permanent establishment risks and recommendation in connection with sale of products in the Korean duty free market.
Advised a major US semiconductor manufacturer on developing strategies for negotiating with the Korean National Tax Service on the issue of royalty sourcing.
Advised various multinational companies on the tax efficient structuring of Korean operation, including entity type, transaction structure, pricing arrangement, etc.