日本の现状と课题JapaneseCurrentStatusandChallenge.pptVIP

日本の現状と課題Japanese Current Status andChallenge IssuesRegarding Partnership Law Reform ２００５．０８．２６ rev.14 Jun Saito Ph.D. in Applied Physics GIST While the Japanese people do not know what the omelet is, they have just broken the egg shell. (An English old saying ; You cannot make an omelet without breaking the egg. 虎穴に入らずんば虎児を得ず。) In Japan, there is no concept of partnership, no actual partnership act, no common custom of partnership accounting, no common custom of partnership taxation. Applications of new type Partnershipin US and Europe ‘Bundling Together LL’：AirBus、ASML、Nokia、Ariane Rocket、AMTC、AMD Fab36 LLC CoK.G. ‘Collaboration to pass over the Death Valley’： EUV-LLC、eLith-LLC、Iridium-LLC ‘Facilitating human capitals’ ： Segway-LLC、Dream Works LLC ‘Facilitating Early Stage IP’：Bell Atlantic IP Holdings LLCVentures from Univs.（ex. Illinois Venture LLC） ‘Mass management of Harvest Stage IPs’　：MPEG L.A. LLC Balance Sheet Accounting v.s. Partnership Accounting Noｔ mandatory to account the cashable assets. Each partner has his own capital account. At each time of transaction, an allocation and/or a distribution is made in the capital account. The allocation list is filed to the tax authority as an information tax return. Partnership Law Reform History 米国LLC＝「法人格」＋「　　 　　有限責任」＋「Partnership会計」＋「パススルー課税」New Partnership Act Comparison Prof. McCahery and Prof. Vermeulen,How about your countries? The biggest feature of US-LLC;Non-recourse and Non-collateralLimited Liability Non-recourse;The liability does not recourse to the partners.The partnership assumes the liability. Non-collateral;In partnership accounting, it is not mandatory to account cashable assets which could collateralize the debt, the loan, or the liability. (Corporate Income Tax Revenue) / (Tax Revenue) The magic formula of LLC“The less, the more.” Challenge Issues for Japanese How to Introduce the concept of Partnership to Japanese people. How to migrate from the tax r