Mr. Jae Young PARK is a partner at DR & AJU LLC. His practice is primarily focused on National Tax & Local Tax, Tax Litigation, Tax Investigation, Administrative Procedure & Litigation, Insolvency & Restructuring, and Shipping & Aviation.
With over 10 years of experience in key positions within the National Tax Service (NTS), Mr. Park is an unrivaled expert in the tax field.
He began his career at the NTS as an administrative officer in 2012 and subsequently held several prominent positions, including the Head of the Investigation Bureau III and the Chief Head of the Inheritance and Gift Tax Litigation at the NTS Seoul Regional Office. He also contributed his expertise to various other departments, including the Collection, the Legal Affairs & PR Bureau at the NTS, the Taxpayer Protection Office at the NTS Seocho District Office, and the Collection, the Legal Affairs & PR Bureau at the NTS Jungbu Regional Office.
During his tenure in the Investigation Bureau III, Mr. Park made notable contributions for a span of 4 years before retiring. He led the composition of key legal principles and provided direction to investigations for cases involving inheritance and gift tax, accumulating a wealth of experience and knowledge.
In particular, he played a key role in the investigation and taxation processes of the Investigation Bureau III of the NTS Seoul Regional Office. He proactively identified attempts of property owners to evade inheritance and gift taxes, established legal grounds for taxation, and created and distributed internal business manuals for the team’s guidance and efficiency.
Mr. Park has handled a number of notable cases, including small building appraisal, spouse deduction to tax evasion on dividend income, gift tax on stock held in secondary nominee name, gift of profits following stock conversion (e.g., convertible bonds), gift of profits following the property value increase after property acquisition, spousal inheritance deduction, gift of profits through transactions with specific corporations, loan of funds between related parties, gift of profits from mergers and listings, and denial of unfair transaction and accounting.
Mr. Park’s proficiency in inheritance and gift taxes has earned him recognition. He served as an adjunct professor at the National Tax Service, dedicating over 100 hours each year to delivering tax lectures to tax officers. He also has been invited to deliver lectures on behalf of the NTS at external organizations. Within the National Tax Service, Mr. Park is highly regarded for his clear and effective action plans, earning him the trust and respect of his peers and colleagues.
Moreover, Mr. Park has been a member of the NTS Seoul Regional Office Taxation Facts Judgement Advisory Committee for 7 years, an organization that deliberates on issues that arise during tax investigations and taxation.
Advised on the valuation of the stock following a capital increase under the Discounted Cash Flow Act when stocks are reallocated to a related party at a high price (third-party allocation)
Advised on determining and defining related parties under the Tax Act
Advised on the inheritance tax matters where stocks of a deficit corporation are retransferred through a paid-in capital increase
Offered advice and representation in litigation concerning the revocation of gift tax on a constructive gift for nominal trust through indirect stock ownership by the head of a large company and stock listing
Advised on the market price evaluation of small buildings under the Inheritance Tax and Gift Tax Act
Advised on taxation of gains on the increase in property value after acquiring stocks of a sales company
Represented the client in a lawsuit seeking the cancellation of gift tax and income tax imposition (related to a trust held in a secondary nominee name) through the title trust of the owners of a large company
Represented the client in a lawsuit to cancel tax imposition resulting from a duplicate tax investigation
Advised on gift tax of funds reverted to a former spouse due to property division following a divorce
Advised and carried out a lawsuit involving income tax evasion through tax havens
Provided a number of consultations and carried out lawsuits involving other property taxes within the National Tax Service