YOON&YANG

• 2008-present Yoon & Yang LLC
• 2024-present Academic Director, Korean Academic Society of Taxation
• 2023-present Auditor, NDREAM
• 2007-08 Ernst & Young
• 2005-07 Samil PwC
• 2001-05 Samjong KPMG

• 2002 Sogang University, B.A. in Business Administration
• 2000 Sogang University, B.S. in Life Science

[Tax Advisory ∙ Tax Strategy]

• Planning of spin-off of holding company and split of affiliate pursuant to the Monopoly Regulation and Fair Trade Act (the “Fair Trade Act”)
• Planning of transition to a general holding company through split-off of the business division of a non-listed company
• Planning of transition to a holding company under the Fair Trade Act through split-off of the business division of a listed company
• Planning of governance restructuring through listing and division of a non-listed company
• Planning of governance restructuring through division and merger of multiple group companies
• Review of tax issues regarding split-off of business division for management efficiency of a financial company
• Review of tax issues regarding merger of subsidiary for management efficiency of a manufacturing company
• Review of deal structure regarding partial sale of business division for participant of a real estate development project of a Vietnamese company
• Review of inclusion of settlement amount in tax calculation, which was paid during the litigation seeking damages regarding infringement of trade secrets filed by a domestic company in the US
• Review of adequacy in taxation as to capital gains of a controlling shareholder by exercise of right to conversion of bonds on the condition of call option issued by a listed company
• Review of applicability of deemed gift tax upon neglection of duty in entry of change of shareholder of inherited shares
• Review of applicability of the Regulation on Denial of Calculation of Wrongful Act regarding receipt of consideration for trademark use

[Tax Trial]

• Motion for adjudication as to disposition imposing residential tax against a hospital associated with a school
• Motion for adjudication as to disposition imposing corporate tax upon deeming gratuitous transfer of designated party exercising call option of convertible bonds
• Motion for adjudication as to disposition imposing corporate tax upon collection of reduced corporate tax related to relocation of a provincial region
• Motion for adjudication as to disposition imposing corporate tax and acquisition tax against repurchase following acquisition of industrial complex land
• Motion for adjudication as to disposition imposing corporate tax upon denial of calculation of wrongful act relating to non-receipt of interest as to loans by a domestic company from a subsidiary
• Motion for adjudication as to disposition imposing corporate tax upon denial of recognition of deductions of losses incurred by calculating the acquisition price in consideration of provisioning not recognized as deductions for tax purpose upon assignment of business division by a domestic company to a special related party
• Motion for analogical interruption as to issues involving division of a company that transitioned into a holding company
• Motion for analogical interruption as to issues involving gift tax from funneling upon transfer/acquisition of business division

[Tax Litigation]

• Assisted in the administrative suit of a case relating to the taxation exclusion period due to failure to file real estate capital income in the tax base by a non-profit company
• Assisted in the administrative suit of a case relating to the disposition imposing corporate tax upon deeming of a Hong Kong company’s domestic subsidiary
• Assisted in the administrative suit of a case relating to the disposition imposing acquisition tax in which heavy tax was imposed upon establishment of a branch by an insurance company
• Assisted in the administrative suit of a case relating to disposition imposing corporate tax as to non-recognition of interest paid on real estate not used for business following succession of a real estate split-off entity through split-off of a real estate transaction company 
• Assisted in the administrative suit of a case relating to whether subsidies received from the state related to public services provided by a public corporation are subject to value-added tax
• Assisted in the administrative suit of a case relating to the period of effectuation of inclusion of an affiliate under the Fair Trade Act, which is precluded from application of special taxation on the grounds of falling under a small and medium-sized enterprise (SME)
• Assisted in the administrative suit of a case relating to imposition of acquisition tax against oligopolistic shareholders including third-party shareholders
• Assisted in the administrative suit of a case relating to whether loans can be recognized as deductions, in which grounds for bad deduct occurred following severance of special interest relationship
• Assisted in the administrative suit of a case relating to whether taxation as to gains reaped by a shareholder from an unfair inclusive share swap falls under profit & loss transaction or capital transaction
• Assisted in the administrative suit (final appellate proceeding) for the defendant as to disposition imposing income tax upon sale of Star Tower shares 
• Assisted in the administrative suit (final appellate proceeding) for the defendant as to disposition imposing corporate tax as to asset revaluation gains

[Criminal Defense]

• Assisted in the administrative suit (final appellate proceeding) of a case related to evading dividend income & capital gains tax upon holding and managing inherited third-party shares/evading corporate tax upon procuring and using off-balance funds through window-dressing
• Assisted in the administrative suit of a case related to a Hong Kong company, which is deemed a domestic entity, being charged with evading corporate tax on the grounds of concealing that it met the relevant taxation requirements
• Provided advisory service in a criminal case where a company was charged with evading corporate tax by non-recognition of assets in the book which was succeeded following the merger of an insolvent affiliate

• Restriction of Special Taxation Act - Articles 30-5 through 43 (Co-author, LAWnB Online Commentary, 2022)
• Income Tax Act - Articles 12 through 22, (Co-author, LAWnB Online Commentary, 2017)
• Tax Law Issues related to Corporate Division under the Commercial Act, Study on Tax Practice 2, Yoon & Yang LLC (2017)
• Tax Law Issues related to Capital Transaction under the Commercial Act, Study on Tax Practice 1, Yoon & Yang LLC (2015)
• Tax Law Issues related to Merger under the Commercial Act, Study on Tax Practice 1, Yoon & Yang LLC (2015)
• Corporate Division and Tax Law – Focusing on Required Qualifications, BFL Journal No. 8, Center for Financial Law at Seoul National University (Co-author, 2013)