YOON&YANG
Rham Joon Park Attorney
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  • TEL 02 6003 7555
  • FAX 02 6003 7032
  • E-MAIL
Rham Joon Park is an associate at Yoon & Yang LLC and his practice areas are tax consulting, tax trial and tax litigation.
Prior to joining Yoon & Yang, Mr. Park worked in the Audit Division of Samil PricewaterhouseCoopers (PwC) from 2008 to 2013, where he performed external audits and corporate financial due diligence.During this period, he also served as an Air Force Accounting Officer, holding positions such as Disbursing Officer, Contracting Officer, and Eligibility Review Officer. After obtaining his license as an attorney, he successfully handled tax litigation, corporate and commercial litigation, and general corporate advisory matters, specializing particularly in dispute resolution for accounting firms. Currently at Yoon & Yang, he focuses on building expertise in the fields of tax litigation and tax advisory services.

Experience

  • 2021-present Yoon & Yang LLC
  • 2020-21 Hankyul Law Group
  • 2019-20 Pyeong An Law Firm
  • 2010-13 Accountant Officer, Republic of Korea Air Force
  • 2008-13 Certified Public Accountant, Samil PwC

Education

  • 2017 Korea University School of Law, J.D.
  • 2009 Korea University, B.A. in Business Administration

Qualifications

  • Admitted to bar, Korea (2019)
  • Certified Public Accountant, Korea 2008)

Representative Matters

[Tax Litigation] 

  • Dispute regarding whether royalties for patents unregistered in Korea constitute domestic source income
  • Dispute over the calculation of the foreign tax credit limit for major domestic construction companies
  • Dispute concerning the deductibility of employment levies for the disabled
  • Dispute regarding the existence of a permanent establishment (PE) for a corporation
  • Dispute concerning the tax reduction scheme following the relocation of a head office
  • Dispute regarding capital gains tax reduction for rental housing businesses
  • Dispute over the classification of land as non-business use property
  • Dispute regarding the global income tax of co-entrepreneurs (joint business operators)
  • Dispute over the classification of payments as gratuities
  • Dispute concerning the issuance of fabricated tax invoices
  • Dispute regarding the scope of small and medium-sized enterprises (SMEs) under the Restriction of Special Taxation Act
  • Dispute over the recognition of goodwill in an equity transfer agreement
  • Dispute regarding the supplementary valuation method for unlisted shares
  • Dispute concerning the imposition of acquisition tax following the cancellation of an in-kind contribution agreement
  • Dispute regarding the supplementary valuation method for unlisted shares
  • Dispute over whether property was directly used for business purposes to qualify for local tax reduction
  • Dispute concerning the provisions for excluding the application of heavy taxation rates under the Local Tax Act
  • Dispute regarding the valuation of de facto roads
  • Dispute concerning the presumptive gift tax on name trust arrangements
  • Dispute regarding the imposition of the comprehensive real estate holding tax (JongBuSe) on rental housing businesses

 

[Tax Advisory]

  • Advisory on tax issues related to the transfer of unlisted shares
  • Advisory on the deductibility of bad debts for overseas receivables
  • Advisory on tax issues related to corporate spin-offs
  • Advisory on tax issues related to the mutual cancellation of a sales contract
  • Advisory on the division of the estate
  • Advisory on stamp tax issues

Languages

Korean and English