We are pleased to announce that Hirohiko Shinbayashi, a graduate Graduate School of Accounting & Finance, MBA Program, has been awarded the 30th Tax Museum Encouragement Award from the Tax Museum, a public interest incorporated foundation.
Received the 30th Tax Museum Encouragement Award from the Tax Museum, a public interest foundation
Hirohiko Shinbayashi (Graduate of Graduate School of Accounting & Finance, MBA Program)
Title: "A consideration of the timing of profit and loss attribution under the Corporation Tax Law regarding subsequent events: Focusing on an analysis of court cases including the issue of determining the liability to return interest in excess of the limit"
In order to support tax law studies and academic research closely related to tax law, the Tax Museum selects the Tax Museum Award every year for outstanding books and papers on tax law, etc. The Tax Museum Award is an award given to books and papers on tax law, etc., and the Tax Museum Encouragement Award is given to papers written by graduate students.
*Details about the Tax Museum Awards can be found on the Tax Museum's official website.
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Comment from the winner
I am extremely pleased to receive this prestigious Tax Museum Encouragement Award.
This paper attempts to provide a comprehensive and systematic review of the issue of "when a change in the taxable facts occurs subsequently, should this be adjusted through current year adjustment or retroactive amendment under the Corporation Tax Law?"
Among these, through the case of a consumer finance company that had gone bankrupt and been found liable for the return of interest in excess of the limit, the court considered whether it was appropriate from an interpretational point of view that "even for corporations whose going concern premise has collapsed, current year adjustments are forced on them based on Article 22, Paragraph 4 of the Corporation Tax Act (Fair Processing Standards), and that relief in the form of a reduction in tax payments is not adequately provided," and if so, what future direction, including legislative measures, could be considered.
I believe this is a familiar issue in tax practice, so I would appreciate it if you could take a look at even just the summary.
I would like to take this opportunity to thank Dr. Koichi Saito, my advisor Professor, and all the other professors and staff at the Graduate School for their assistance in writing this article.
Comments from supervisors
Congratulations, Shinbayashi-san, on winning the Tax Museum Award.
As the professor in charge, I am extremely pleased that the results of the research that the students have worked so hard on have been recognized by a specialist institution outside the university.
Regarding the timing of recognizing profits and losses due to subsequent events, retroactive accounting standards were enacted in corporate accounting about 10 years ago, but there is a question as to how this should be treated under the Corporation Tax Law.
In this case, the question of whether to make retroactive adjustments or current year adjustments will only change the carryover profits in accounting terms, but in tax terms, the amount of tax may fluctuate. Also, in relation to the principle of tax law, certain criteria are required to ensure legal stability and predictability.
Subsequently, in response to the revision of the revenue recognition standards based on international accounting standards, the Corporation Tax Act was amended in fiscal 2018 to create a new Article 22-2 of the Corporation Tax Act, but this has not resolved the above issues.
Mr. Shinbayashi has studied these issues, focusing mainly on the analysis of court cases, such as the issue of determining the debt to repay interest in excess of the limit, and has come up with extremely meaningful recommendations.
We believe that the research content and recommendations will have an impact on future researchers in this field.
We wish Shinbayashi-san even greater success in the future.
Finally, a word to current students: at our graduate school, students go through several stages before completing their thesis, including case study research in each seminar, deciding on a thesis topic, formulating a research plan, and making an interim presentation.
I'm sure you are all busy in your own environments and positions, but I hope that you will work hard at each step on a topic that interests you, and finish up a thesis that you are satisfied with. I hope that you will make it a fond memory of your time at graduate school.
(Supervisor: Visiting Professor Koichi Saito)
Previous years' Tax Museum Award and Tax Museum Encouragement Award winners
- 2019 28th
Title: "Various tax issues related to virtual currencies and tokens: Focusing on the current state of income taxation and future taxation"
Mr. Fuyuki Shibata, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Koichi Saito) - 2018 27th
Title: "Issues with the Special Taxation Measures Act as an Investment Promotion Tax System: An Examination of Special Taxation Measures and the Patent Box Tax System as Investment Incentives"
Graduate School of Economics (SME Management Consultant Training Course) Graduate, Atsushi Arakaki (Supervisor: Professor Yoshio Tai) - 2015 24th
Title: "Securing International Taxing Rights and Addressing Base Erosion: Reconsidering the Principles of International Division on International Double Non-taxation"
Mr. Kuniyasu Inami Visiting Professor Graduate School of Accounting & Finance, MBA Program - 2014 23rd
Title: "A Study on the Tax System for Donations - Focusing on the "Institutionalization of Year-End Adjustment for Donation Deductions""
Daisuke Uemura, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Tsuneo Arima)
Title: "A Study on Consumption Tax: Tax Exemption for Social Insurance Medical Treatment and the So-called 'Loss Tax'"
Mr. Shunsuke Kanehara, Graduate of Graduate School of Accounting & Finance, MBA Program (Supervisor: Professor Satoko Kimoto) - 2012 21st
Title: "Countermeasures against tax avoidance in corporate tax trusts: Countermeasures against tax avoidance through multi-layered schemes using foreign trusts"
Mr. Yasuhiro Fushimoto, Graduate Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Susumu Honjo) - 2011 20th
Title: "Residency rules for inheritance tax"
Mr. Hideto Negishi, Graduate Graduate School of Accounting & Finance, MBA Program (Supervisor: Visiting Professor Susumu Honjo)