• advised clients on tax issues relating to VCC structures
• conducted tax due diligence reviews
• advised on employment tax issues in corporate restructuring affecting many employees of several Singapore companies
• advised clients on consequent tax issues arising after an international tax dispute
• advised local subsidiaries of foreign corporations on tax issues concerning source of income
• represented international corporate clients in long-running disputed matters with IRAS covering several years of assessment, and successfully and expeditiously closed the cases with IRAS on the terms of settlement desired by corporate clients in relation to both taxes and penalties.
• advised corporate clients in transfer pricing issues with IRAS spanning many years of cross-border business operations, and successfully obtained tax refunds from IRAS of withholding taxes in the millions previously paid under protest
• advised clients (including businesses and companies) under tax audits by IRAS
• advised corporate and individual clients under investigation by IRAS for income tax evasion
• advised multinational clients on effective tax structuring for holding and exploitation of intellectual property in corporate group structuring
• advised resident and non-resident corporate clients on imposition of taxes for royalties and other payments for intellectual property rights
• advised clients in merger and acquisition transactions, including on indemnities and warranties in the deal documentation in corporate restructuring
• advised clients on requests for information made by foreign tax authorities to IRAS under exchange of information articles in double taxation agreements
• advised clients on goods and services tax in relation to import of goods, supply of goods and services in Singapore, zero-rated international services and requirements of registration
• provided legal opinions on company & tax law in cross-border corporate restructuring
• represented clients under investigations by IRAS for income tax evasion, and achieved successful settlement of all tax liabilities for the years under investigation, without publicity or court prosecutions
• advised clients on interpretation of tax and other legislation, and tax efficient strategies in corporate restructurings, mergers and acquisitions, and liquidations, and legal opinions, e.g. on imputed profit margins by IRAS
• advised clients on taxation issues for stock options in parent company granted pursuant to employee group stock option and share option schemes
• advised international clients on unwinding cross-border tax structure set up upon advice of other professional tax advisers
• advised financial institutions and listed corporations on domestic and international corporate and tax structuring and on advance rulings by IRAS
• negotiated successfully with IRAS investigators in cases headed for prosecution, and closed all these cases privately without charges for tax evasion being issued or appearance in court required of the affected taxpayers
• advised clients on cross-border tax issues and legal liabilities involving Singapore and other countries, including on comprehensive double taxation agreements
• provided tax analysis to clients on various legal matters, including M&A deals negotiated successfully with IRAS for clients under tax audits and reduced tax penalties imposed by IRAS over and above the underlying additional income taxes or goods and services taxes, including on directors for alleged interest-bearing loans