General

Working closely with our clients on complex transactional structures, in addition to providing general consultation relating to Korean tax laws, Kim Chang Lee provides our clients with innovative plans and structures that minimize the impact of Korean and foreign taxes while effectively achieving their business objectives. Our tax specialists possess deep expertise in this practice area and also represent our clients in tax-related litigation and disputes. We maintain close working relationships with the tax authorities in Korea and outside tax/accounting experts, which enables us to provide optimum solutions to our clients in highly complex and technical tax matters.

Corporate Tax

Virtually all corporate transactions require substantial consideration of tax consequences. Our tax practice ranges from advising on financial reportings to counseling on general tax laws and structuring transactions to meet the clients’ needs with efficient tax results.

Our attorneys plan, structure, negotiate and implement numerous forms of business transactions, including mergers, acquisitions, reorganizations, restructurings, leveraged buyouts, recapitalizations, joint ventures and leasing transactions, based on a thorough analysis of various tax considerations aimed at formulating the most efficient tax plan. Kim Chang Lee advises clients on the tax effects of public and private offerings of various types of debt and equity instruments, including convertible securities and other hybrid instruments, and various forms of asset-based securitization, such as those involving securities backed by loans, mortgages, credit card receivables and leases. Kim Chang Lee provides our clients with innovatively designed financial products and business structures by analyzing legislative and regulatory developments relating to tax affecting our Korean and foreign clients, including multinational corporations, investment and commercial banks, private equity funds and individuals. Our attorneys also advise and represent clients in connection with Korean and international tax controversy matters in all phases of the dispute resolution process.

Corporate Tax: Mergers and Acquisitions

Kim Chang Lee always endeavors to provide tax advice that suits the particular needs of our clients. We understand that virtually no merger or acquisition can take place without substantial consideration of the tax consequences of the proposed transaction. In this regard, our attorneys work closely with internal tax staff and outside accountants to design each transactional structure to meet the clients’ objectives with efficient tax results in the context of a particular transaction. Our practice includes analyzing transactional structures based on Korean and foreign statutory and regulatory requirements for tax consequences, and examining the tax considerations of the proposed targets for merger or acquisition.

International Tax

Our attorneys regularly provide practical tax advice focusing on each of our clients' needs with their international business activities. Kim Chang Lee has extensive experience in general tax consultation and strategic tax planning in connection with cross-border transactions. Our attorneys work with tax accountants and advisors in Korean and various foreign jurisdictions to develop structures that are tax efficient from both a Korean and foreign tax perspective. Our international tax practice includes structuring cross-border mergers, acquisitions, divestitures, restructurings, leases and financings, and advising on foreign investments, international joint ventures and international project financings.

A recent trend in the international tax area has been the increasingly active sharing of information among tax authorities around the globe to regulate tax avoidances using tax havens. Kim Chang Lee provides superior tax advisory services on key tax issues relating to determination of residency, permanent establishment, income attribution under tax treaties, beneficial owner, and transfer pricing, among others. We also have a strong track record of successfully representing our clients in international tax controversies that arise from such tax issues.

Tax Controversy

We have considerable experience representing clients at all levels within the National Tax Service and other government agencies. Kim Chang Lee also acts as litigation counsel before the courts when resolution is not possible at the administrative level. Our attorneys have acted on behalf of clients on a wide range of issues including not only substantive tax matters, but also procedural tax matters such as search, attachment, seizure, and claims for privilege. Kim Chang Lee also regularly represents clients in cross-border tax law matters, such as customs and excise tax matters.

• Global industrial gas manufacturer’s Korean subsidiary on the tax aspects of restructuring of its ownership structure
• Foreign-based software company in an international arbitration involving withholding tax on its royalty income in Korea
• Global golf equipment manufacturer on the tax aspects of restructuring of its Korean business
• Domestic cosmetics company in a criminal case involving alleged violations of customs laws
• Domestic commercial vehicle manufacturer in connection with a tax audit
• Multinational companies and major foreign universities on the tax aspects of their business activities in Korea
• Multinational companies without a permanent establishment in Korea on the applicability of tax treaties in respect of their Korean-source income