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Tax Disputes and Tax AuditsFrom tax audits through requests for reconsideration after a reassessment to tax litigation, our attorneys handle each stage, dividing roles with your retained tax accountant.

Free consultation Why LegalAgent
Response time
1 business day*
First consultation
30 min free
Stages covered
Tax audits · Appeals · Tax litigation

* As a rule, for contract reviews and routine legal questions. For complex or urgent matters we propose a schedule that fits the matter.

Client companies served*

150+

Selected clients shown, in no particular order. * Clients and partners. Not limited to Tax Disputes and Tax Audits matters.

KADOKAWA FRONTEO YAMAP ACROVE LAPRAS AVA Intelligence OPTIEUM Biotechnologies ReDelta Concrew LINEA Innovations TECHSUITE YStory

Handling the legal arguments and procedures from tax audits to tax litigation

We provide legal and dispute support from your exchanges with the authorities during a tax audit, through requests for reinvestigation and requests for reconsideration to the National Tax Tribunal after a reassessment, to tax litigation. We respect tax calculations and filing practice as the specialist domain of your retained tax accountant, and our attorneys take on contract interpretation, fact-finding, evaluation of evidence and the procedures for appeals and litigation. We examine separately whether each finding by the authorities rests on fact-finding or on the interpretation of laws and regulations.

  • Your views conflict with the authorities over how a transaction is characterized
  • You have received a reassessment and need to decide whether to appeal, and by when
  • The matter is moving ahead without a clear division of roles with your tax accountant
  • Records of exchanges with the tax examiners are not organized

Why LegalAgent

With LegalAgent, you can build your arguments while sharing the work with your tax accountant

We support your response to the tax authorities in three ways: fast answers, fees you know before we start, and an analysis of the issues you can share with your tax accountant.

  1. 01Speed

    Typical law firms3–5 business days

    LegalAgent1 business day, as a rule

    We check filing deadlines first

    We answer contract reviews and routine legal questions within one business day as a rule. Because filing deadlines are set according to the type of disposition, we first confirm the procedural stage and the deadline.

  2. 02Fees

    Hourly billingTotal unknown at the start

    LegalAgentScope and fee set before we start

    We set the scope by stage: audit or after a disposition

    We ask whether the matter is at the audit stage or at the stage of a request for reconsideration or litigation after a disposition, and how many issues are in dispute, and give you an estimate before we start. If the procedure moves to the next stage, we update the estimate and explain it to you.

  3. 03Coordination

    • Division-of-roles memo
    • Issue-sharing materials
    • Draft outline of arguments
    • Draft appeal documents

    Your tax accountant handles tax calculations; attorneys handle legal arguments

    Building on the tax calculations and accounting treatment confirmed by your tax accountant, we separate out the issues of contract interpretation and fact-finding and share the points each side needs to confirm.

* Response times are for contract reviews and routine legal questions; they vary by matter.

How it works

The AI Agent organizes the audit records; attorneys build the rebuttal

The AI Agent organizes the facts from the notice of disposition, records of questions and answers and contracts you provide; attorneys judge whether each finding rests on fact-finding or on the interpretation of laws and regulations.

AI Agentdoes the work

  • Organizes the exchanges from records of questions and answers and submitted materials
  • Extracts facts relevant to the findings from contracts and internal approval documents
  • Drafts requests for reconsideration and briefs

Attorneysmake the judgment

  • Judge whether a finding rests on fact-finding or on legal interpretation
  • Decide among a request for reinvestigation, a request for reconsideration and litigation
  • Take responsibility for the final arguments and appeal documents
ConsultationDocuments and dealings with the authorities
  1. STEP 01Confirming the status of the audit or disposition

    Confirm the current procedural stage, the findings or reasons for the disposition and whether there is a filing deadline

    Memo on the situation and consideration of the response schedule

  2. STEP 02Organizing the facts and evidence

    Check the facts underlying the findings or disposition against the evidence and organize the material for a rebuttal or arguments

    Factual analysis table, list of evidence

  3. STEP 03Sharing issues and confirming the division of roles with the tax accountant

    Separate tax calculation issues from legal argument issues, and set out the division of roles with the tax accountant and the points each side needs to confirm

    Memo on the division of roles, materials for sharing issues

  4. STEP 04Considering the appeal and response strategy

    Consider the structure of the arguments for each option, the evidence required and the procedures for filing

    Memo comparing the options, draft outline of arguments

  5. STEP 05Preparing documents and dealing with the authorities

    Prepare appeal documents or briefs and support exchanges with the authorities

    Draft appeal documents, status reports

  • Attorneys make the final callAn attorney checks every deliverable and takes responsibility for it.
  • Your inputs are not used to train AIOn top of attorneys' statutory duty of confidentiality, we work in an environment where your inputs are not used to train AI.
  • An AI Agent built in-houseOur own engineers develop it. Information Security Policy

Use cases

Common requests and what you receive

From findings in a tax audit to appeals after a reassessment and tax litigation, this map shows, for each situation involving exchanges with the authorities, the effect of leaving it unaddressed and the analysis and deliverables LegalAgent provides.

  1. 01

    Our views conflict with the authorities in a tax audit over how the nature of a transaction is characterized

    If left aloneIf the response proceeds without organizing the legal basis for the findings, it may develop into a finding of additional income or heavy additional tax and lead to a reassessment

    What we doReview the authorities' findings, exchanges such as records of questions and answers, and related contracts and internal approval documents, and determine whether the findings rest on fact-finding or on interpretation of laws and regulations

    What you receive
    • Table of findings
    • Outline memo for a rebuttal
    • Materials for sharing issues with the tax accountant

  2. 02

    We have received a reassessment notice and want to decide whether to file an appeal

    If left aloneWhile time is spent considering the options, the filing deadline may pass and the opportunity to appeal may be lost

    What we doReview the disposition, the reasons given and the evidence on hand, and set out the structure of the arguments and the procedural outlook for each option: a request for reinvestigation, a request for reconsideration and filing a lawsuit

    What you receive
    • Memo comparing the options
    • Outline of the appeal documents
    • Internal explanatory materials

  3. 03

    Our retained tax accountant has recommended consulting an attorney on the legal analysis

    If left aloneThe response proceeds while the division of roles between tax calculations and legal arguments remains vague, and answers to the authorities and arguments lack consistency

    What we doBased on the tax calculations and accounting treatment confirmed by the tax accountant, set out the legal and dispute issues, such as contract interpretation, fact-finding and evaluation of evidence, and clarify the division of roles

    What you receive
    • Issue table
    • Memo on the division of roles with the tax accountant
    • Draft outline of arguments

  4. 04

    We want to organize records and arguments from the early stages of the audit

    If left aloneThe audit proceeds with insufficient records of exchanges with the examiners, and arguments lack support later at the appeal or litigation stage

    What we doReview exchanges such as records of questions and answers, submitted materials and related contracts, and record and organize the facts from the audit stage

    What you receive
    • Table of records of exchanges
    • List of submitted materials
    • Initial response memo

Scope of our tax dispute and tax audit support

Divided into the tax audit stage, the appeal stage after a disposition and coordination with the tax accountant, we show the points we review, the legal judgments we make and the deliverables.

Response at the tax audit stage
We organize the authorities' findings and the records of exchanges, and confirm the legal basis for the findings.
  • Audit response and organizing the facts
  • Organizing evidence and records
Appeals and tax litigation after a disposition
We review the content of the reassessment or similar disposition and support the preparation of the documents needed at each stage of the appeal and litigation.
  • Setting out the appeal options
  • Support in preparing appeal documents and briefs
Coordination with the tax accountant and internal response
We set out the division of roles between the tax calculation side and the legal argument side, and pull together material for internal decisions.
  • Setting the division of roles with the tax accountant
  • Internal explanations and response strategy

Our approach

What we focus on in Tax Disputes and Tax Audits

In tax disputes and tax audits, we place weight on the following perspectives.

  1. 01

    Examining the legal basis of the findings by separating fact-finding from legal interpretation

    We distinguish whether the authorities' findings rest on an evaluation of the facts, such as contract interpretation or the characterization of a transaction, or on the interpretation of laws, regulations and circulars, and consider how to build a rebuttal suited to each.

  2. 02

    A division of roles based on the tax calculations and accounting treatment confirmed by the tax accountant

    We respect tax calculations and filing practice as the tax accountant's specialist domain, and confirm early in the matter a division in which the attorney handles contract interpretation, fact-finding, evaluation of evidence and the procedural side of appeals and litigation.

  3. 03

    Emphasizing the organization of records from the audit stage

    Rather than organizing records only after a disposition is issued, we organize exchanges and submitted materials early in the audit stage, securing consistency of arguments in any later appeal or litigation.

  4. 04

    Setting priorities according to the procedural stage and filing deadlines

    Because filing deadlines and procedural stages are set according to the type of disposition, we first confirm the current procedural stage and whether there is a deadline, and then set the priorities for the response.

Pricing

Tax dispute and tax audit fees

The work required differs depending on whether the matter is at the tax audit stage or at the appeal or litigation stage after a disposition, so we provide an estimate after hearing about the situation. When preparing an estimate, we confirm the following points.

How fees are set

Scope and fee agreed before we start

Matter-based work is generally on a fixed fee. For complex or urgent matters, we propose a schedule and an estimate that fit the matter.

First consultation

A free 30-minute online meeting.

You can come to us before your documents are in order. Tell us what you know so far.

Free consultation

What we check before quoting

  • Stage of the response (audit stage, after disposition, request for reconsideration or litigation)
  • Number of issues in dispute and complexity of the facts and evidence
  • Status of coordination with your retained tax accountant or other professionals and the scope of points to confirm
  • Volume of submitted materials and related contracts
  • Expected number of exchanges with the authorities and hearing dates

If the matter moves from the audit stage to the appeal or litigation stage, we update the estimate according to the change in procedural stage and explain it to you.

Team & Record

Attorneys who know business practice handle your matters

Contract reviews and drafts
2,000+
Client companies
150+
Startup legal matters
200+
Legal and investment DD
20+

* Approximate figures based on matters handled by our firm; actual figures vary by matter.

Engineers

Shinya Makita and Sota Miya build our product on the same team as the attorneys.

Practical guides to tax disputes and tax audits

Tax appealsTax Audits and Appeals Against Reassessments: Deadlines for Requests for Reinvestigation, Requests for Reconsideration and Tax Litigation

If a company follows the recommendation in a tax audit to file an amended return, it can no longer dispute that tax amount through an appeal. With reference to the statutory provisions, this article reviews the deadlines for requests for reinvestigation and requests for reconsideration after a reassessment and how to choose between them, the exhaustion requirement and the period for filing suit, the records to keep at the audit stage, and the division of roles between the company's retained tax accountant and attorneys.

Related practice areas

FAQ

Frequently asked questions

If we have a retained tax accountant, do we need to engage an attorney separately?

Because tax calculations and filing practice are the specialist domain of your retained tax accountant, we work on the premise that you will continue to engage the tax accountant for them. Our firm supports the legal aspects, such as contract interpretation, fact-finding, organizing evidence and the procedures for appeals and litigation, while dividing roles with the tax accountant.

Can we consult you partway through a tax audit?

You can consult us from the early stages of the audit. Even if records of exchanges with the examiners and materials already submitted have not been organized, we proceed to organize the facts while reviewing the findings and the materials on hand.

We have just received a reassessment notice. What should we prepare?

You can begin a consultation by presenting what you have on hand, such as the notice of disposition and the contracts and transaction materials on which the findings were based. Because the filing deadline is set according to the type of disposition, we first review the content of the notice of disposition.

Should we choose a request for reinvestigation or a request for reconsideration?

After reviewing the disposition, the issues in the findings and the evidence on hand, we set out the structure of the arguments and the procedural outlook for each option. Filing deadlines differ by type of disposition, so we confirm them individually.

Can you handle the matter if it proceeds to tax litigation?

We also handle tax litigation where a request for reconsideration does not resolve the matter, including organizing the facts and preparing briefs.

Can we engage you only to prepare a legal opinion on a specific issue?

We also accept engagements limited to preparing a legal opinion on a specific issue. You can also engage us continuously from the audit stage through appeals and litigation.

Can we consult you if we need an urgent response?

You can also consult us on highly urgent matters, such as where a filing deadline is approaching. The time required for review is adjusted according to the content of the disposition and how far the evidence has been organized.

Where should we consult about civil transaction disputes versus tax disputes?

Commercial disputes that do not involve the tax authorities, such as contract termination or receivables collection with business partners, are handled on the Litigation and Dispute Resolution page. This page focuses on audits, dispositions, appeals and litigation involving the tax authorities.

Contact

Talk to us about responding to tax audits and dispositions

Even if the notice of disposition and records of exchanges with the authorities have not been organized, we accept consultations based on the information known at this point.

  • A free 30-minute online first meeting
  • You can consult us while keeping your tax accountant engaged
  • You can consult us from the early stages of a tax audit