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Global Tax Advisory Office
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Takashi AsayamaTakashi Asayama

California CPA (License # 50276)

Personal History

  • 1984-1987 A "Big 8" Accounting firm, Los Angeles, California
    Audit Senior
  • 1987- 1988 A "Big 8" Accounting firm Tokyo, Japan
    Audit Senior
  • 1988-1993 A California partnership of A "Big 8" accounting firm and one of the biggest accounting firms in Japan Audit
    Partner in Japan Business Group
  • 1993-2001 A "Big 6" accounting firm, Los Angeles, California
    Partner in International Tax
  • 2002-2005 A large accounting firm, Tokyo, Japan
    Partner in International Tax (Transfer Pricing)
  • 2006-Present Takashi Asayama Global Tax Advisory Office

Mission Statement

Over the years, the United States of America has been always the most important partner for Japan, and many people believe that this will continue to be the case for quite some time in the future as well. Especially, in economic sense, the prosperity of Japan has been attributable mostly to a productive relationship with the United States especially after the end of the World War II.

In terms of trade/economic relationship, the inter-company pricing issue has been one of the most critical issues for both countries. That is, " Is the price traded between the parent and its subsidiary company fair?"" Not only the company's personnel but also many people including tax authorities of both countries and economists have spent millions of hours and dollars to reach a good solution to solve this apparently simple, yet perplex problem, but in vain.

In this extremely complex global economic world, it is critical to allocate a fair share of profit among the countries that contribute to the business entity's global economic activities. Until today, each country that contributes to the global profit has been trying to maintain fair share of profit that they believe it is entitled to by arguing a reasonable inter-company pricing issue according to their own domestic tax laws, yet none of those countries have reached a common inter-company pricing method. Therefore, it is critical to identify/determine the common inter-company pricing method that each company can agree to in this complex global economic world.

We believe that it is possible and doable that we can reach to a consensus of adopting a reasonable, rather easy and simple to understand method that we can use in order to apportion the global profit of the business by properly recognizing the degree of the business contributions and associated risks.

For that, our company, Global Tax Advisory Office, has been trying to assist to develop such methodology, not only for the taxpayers and but also tax authorities. Global Tax Advisory Office has been particularly useful in creating a reasonable global income allocation model, and assisting negotiation with tax authorities to obtain an advance agreement of inter-company pricing among the related entities.

 

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