본문
柳成贤
合伙律师

- TEL 82 2 6003 7005
- FAX 82 2 6003 7032
- E-MAIL shryu@hwawoo.com
简介
Sung Hyun Ryu is a partner at Yoon & Yang LLC and his main practice area is tax.
Mr. Ryu utilizes the extensive knowledge and practical experience gained during his time as a deputy director at the National Tax Service to demonstrate expertise in tax advisory, tax disputes, and international taxation. In particular, through his rich experience handling various tax dispute procedures, such as pre-tax examination reviews, objections, audits, appeals, and litigation, he provides exceptional legal services to his clients.
Mr. Ryu utilizes the extensive knowledge and practical experience gained during his time as a deputy director at the National Tax Service to demonstrate expertise in tax advisory, tax disputes, and international taxation. In particular, through his rich experience handling various tax dispute procedures, such as pre-tax examination reviews, objections, audits, appeals, and litigation, he provides exceptional legal services to his clients.
经历
- 2025-present Yoon & Yang LLC
- 2025-present Member, Personnel Committee, Korea Sailing Federation
- 2023-present Member, KOSDAQ Listing Review Committee, Korea Exchange
- 2022-present Legal Advisor, e-KBS
- 2022-present Advisory Member, Disciplinary Committee, Korea Customs Service
- 2019-present Commentator of Tax Cases, Daily NTN
- 2019-present Director, International Fiscal Association Korea
- 2015-present Director, Finance & Tax Forum
- 2014-present Member, Tax Committee, Korean Bar Association
- 2022-23 Member, Evaluation Committee on Virtual Assets, Hankyung TV
- 2021-22 Legal Advisor, NTS Seoul Regional Office
- 2020-21 Advisory Member, National Assembly Research Service
- 2016-17 Commentator of Tax Cases, Law Times
- 2015-19 Member, Legislative Enactment Support Committee, National Assembly
- 2015 Advisory Member, Financial Services Commission
- 2014-15 Legal Advisor, NTS Seoul Regional Office
- 2013-15 Member, Taxpayer Advocacy Committee, NTS Gangnam District Office
- 2012-25 Lee & Ko LLC
- 2009-12 Deputy Director, NTS Seoul Regional Office
- 2007-09 HMP Law
- 2006-07 Public-Service Advocate, Suwon District Prosecutor's Office
- 2004-06 Public-Service Advocate, Korea Legal Aid Corporation
简历
- 2018 Duke University School of Law, LL.M.
- 2006 Seoul National University Graduate School of Law (LL.M. course completion)
- 2004 Judicial Research and Training Institute
- 2002 Seoul National University College of Law, B.A.
主要业务事例
- Represented in a lawsuit regarding the evasion of value-added tax in the case of gold bar
- Represented in a lawsuit regarding the cancellation of comprehensive income tax for yen swap transactions
- Represented in a lawsuit regarding the cancellation of corporate tax for B Korea
- Represented in a lawsuit regarding the cancellation of corporate tax for S Group
- Represented in a lawsuit for the cancellation of tax assessments on comprehensive income gift taxation for S Group
- Represented in a lawsuit regarding the cancellation of inheritance tax assessment for K
- Represented in a lawsuit regarding the cancellation of a refusal to refund for L
- Represented in international tax litigation regarding the criteria for determining whether a foreign corporation qualifies as a beneficial owner eligible to apply tax treaties.
- Represented in international tax litigation regarding whether the compensation for patent usage not registered in Korea under the Korea-U.S. tax treaty constitutes domestic source income
奖项
- Next Generation Partner, Tax, Legal500 Asia-Pacific (2019-2024)
- Commendation from the head of National Tax Service in recognition of excellent performance (2011)
论著
[Books]
- Lawyer’s Tax Manual, Korean Bar Association (Co-author, 2014)
- The Truth About Taxation the National Tax Services Does Not Tell You, Leaders book Publications (2012-2020)
- Understanding the Law for Fair Taxation, NTS Seoul Regional Office (Editor, 2011)
[Academic Papers]
- Korean Tax Law Adopts New Simplified Transfer Pricing Rules relating to Low Value-adding Intra-group Services, Legal500, Legalease (2020)
- Gift Tax Issues and Issuance of New Stock During Debtor Rehabilitation, Korean Law Review for Rehabilitation and Bankruptcy Vol. 4., Korean Association of Rehabilitation Bankruptcy Law (2011)
[Articles]
- When the decedent is a non-resident, the limits of inheritance tax liability and succession of tax obligations, Daily NTN (October 25, 2024)
- Indirect benefits received by shareholders of a corporation engaged in business may be subject to gift tax, Daily NTN (September 15, 2023)
- Hiding assets before the establishment of tax liability does not constitute a violation of the Tax Offenses Punishment Act, Daily NTN (October 13, 2022)
- Whether funds for stock acquisition, received as a gift and immediately paid as capital for incorporation, can be considered as directly receiving the stock as a gift, Daily NTN (October 15, 2021)
- Tax Bomb Strikes Separate Billing Law Firm, Law Times (November 18, 2016)
- Withholding issues arising in payment of consideration for foreign registered patents, Korean Legal News (December 28, 2015)
- Foreign entity and issues in applying tax treaties, Korean Legal News (September 29, 2014)
- Embezzlement of the CEO and tax treatment, Korean Legal News (July 28, 2014)
- Whether partnership can be treated as a foreign entity under tax laws, Tax case commentary, Law Times (November 21, 2013)
- Offshor tax evasion and FATCA, Law Times (November 7, 2013)
- Issues regarding payment of patent royalties to foreign corporations and withholding tax, Kyunghyang Newspaper (October 17, 2012)
- Reporting of Foreign Accounts Necessary In Order to Avoid Penalty Bomb, The Kyunghyang Newspaper (June 12, 2012)
- Gift Tax for Borrowed Money from Father to Purchase a House?, The Daily Focus (January 27, 2012)
- U.N. Convention Facilitates International Trade, The Korea Herald (March 19, 2008)
- Infringement on Trade Secrets, The Korea Herald (December 26, 2007)
相关消息
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Korean and English
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Admitted to bar, Korea (2004)