白濟欽
Senior Partner概要
Mr. Je-Heum Baik is a senior partner at Shin & Kim, mainly practicing in the areas of tax litigations and tribunals, tax advisory services, tax investigations and customs.
Mr. Je-Heum Baik has significant experience in litigating corporate tax matters on behalf of financial institutions, large firms and foreign entities. He provides practical and distinguished tax advisory services based on thorough case studies and reviews.
Prior to joining Shin & Kim, Mr. Baik served in various levels of the judiciary for numerous years. Also, during his long career as a tax attorney at the law firm Kim & Chang, Mr. Baik successfully handled prominent tax cases with precedent-setting decisions including the largest tax case in Korea involving KRW 1.7 trillion, accumulating a reputation as the best tax lawyer.
Based on his expertise, Mr. Baik wrote and published the ‘Key Issues of Tax Law I’ and ‘Key Issues of Tax Law II,’ which deal with analysis of important precedents in tax law. He also continuously contributes to the development of the tax law society through active participation in the industry, including as the Chief Training Officer of the Seoul Bar Association’s Tax Training Institute, the Chief Training Officer of the Lawyer Training Institute of the Korean Bar Association, the Chairman of the Tax Law Association and the Chairman of the Korea Local Tax Association.
関連業務内容
経歴
- 2022-PresentShin & Kim LLC
- 2004-2022Kim & Chang
- 2004Visiting Attorney, Fox Rothschild
- 2001Judge, Seoul District Court
- 1998-2001Judge, Tongyeong Branch, Changwon District Court
- 1996-1998Judge, Eastern Branch, Seoul District Court
- 1994-1996Judge, Incheon District Court
- 1991-1994Judge Advocate, Republic of Korea Army
- 1989-1991Judicial Research & Training Institute of the Supreme Court of Korea
- 1987Passed the 31st Higher Civil Service Examination
Activities
- 2024-PresentCustoms Judge, Korea Customs Service
- 2023-2024Chairman, International Fiscal Association Korea
- 2022-PresentMember, Tax Development Deliberation Committee, Ministry of Strategy and Finance
- 2022Chairman, Tax Law Association
- 2020-2021Chief Editor, Tax Law Review, Tax Law Association
- 2019-PresentMember, Advisory Committee, Korea Institute of Local Finance
- 2019-2022Adjunct Professor, Seoul National University, School of Law
- 2019-2021Member, Committee on Development of Local Tax, Ministry of Interior and Safety
- 2019-2021Chief Training Officer, Lawyer Training Institute, Korean Bar Association
- 2019-2021Chairman, Korea Local Tax Association
- 2019-2020Member, Committee on Development Tax System, Ministry of Economy and Finance
- 2019-PresentLAWnB-ONJU Customs Law Lead Author
- 2019-PresentAdjunct Professor, Seoul National University School of Law
- 2018-PresentAdjunct Professor, Graduate School of Science in Taxation, University of Seoul
- 2014-PresentChief Training Officer, Tax Training Institute, Seoul Bar Association
- 2013-2019Auditor, Korea Local Tax Association
- 2013-2017Member, National Tax Ruling Committee, Ministry of Economy and Finance
- 2013-2016Member, Committee on Development Tax System, Ministry of Economy and Finance
- 2012-2019Adjunct Professor, Graduate School of Law, Korea University
- 2012-2017Vice President, Korea Research Society for Customs
- 2012-2016Legal Advisor, Tax and Customs Office, Ministry of Strategy and Finance
- 2012MOJ Committee on Judicial Examination
- 2011-PresentLAWnB-ONJU Adjustment of International Taxes Act Lead Author
- 2011-PresentMember, NYU Tax Practice Council
- 2010-2013Tax Training Institute Professor, Seoul Bar Association
- 2010-PresentMember, Tax Committee, Korean Bar Association
- 2009-PresentVice Chairman, Standing Director, International Fiscal Association Korea
- 2009-PresentVice Chairman, Standing Director, Korean Academic Society of Taxation
- 2009-2011Lecturer, Graduate School of Science in Taxation, University of Seoul
- 2007-2009Member, National Tax Review Committee, Jungbu Regional Office, National Tax Service
- 2007-2014Judicial Research & Training Institute Lecturer
- 2007MOJ Committee on Judicial Examination
- 2006-2021Vice Chairman, Standing Director, Tax Law Association of Korea
- 2006-2010Member, International Tax Law Improvement Committee, National Tax Service
- 2006-2010Member, Self Evaluation Committee, National Tax Service
- 2005-2018Lecturer, Graduate School of Law, Seoul National University
主な実績
- Advised on a case involving a review of the legality of a corporate tax before payment regarding the assumption of carryforwards in reverse mergers between domestic banks
- Advised on a corporate tax case on income classification of overseas communication satellite usage fees
- Advised on a corporate tax case regarding the beneficial owner of a multinational company
- Advised on a corporate tax case regarding the deductibility of holdings in a proprietary account for trust property
- Advised on corporate tax and comprehensive income tax cases regarding the income classification of yen swap deposit forward exchange gains
- Advised on a corporate tax case regarding the revaluation and non-listing of a life insurer’s assets
- Advised on a case involving the cancellation of imposition of a corporate tax regarding capital increase with consideration of a multinational air carrier
- Advised on a corporate tax case regarding the right of a foreign bank to collect national taxes
- Advised on a customs duty appeal case on refund of customs duty on raw materials for export by a domestic refinery
- Advised on a customs duty appeal case on quota tariff for a domestic refinery
- Advised on a corporate tax case concerning the inclusion of allowance for bad debts in deductible expenses of a domestic bank.
- Advised on corporate tax litigation and appeal cases on transfer pricing for multinational and domestic companies
- Advised on VAT litigation and appeal cases on the discountability of the mileage points of foreign and domestic companies
学歴
- 2005Seoul National University, Graduate School of Law (Ph.D.)
- 2004Columbia Law School (Visiting Research Fellow)
- 2003New York University School of Law (LL.M. in Taxation)
- 2002Harvard Law School (International Tax Program)
- 1995Yonsei University, Graduate School of Business Administration (MBA)
- 1994Seoul National University, Graduate School of Law (LL.M.)
- 1988Seoul National University, College of Law (LL.B.)
資格
- 1991Korea
- 2004New York
所属
- Korean Bar Association
- New York State Bar Association
- America Institute of Certified Public Accountants [2004]
言語
Korean, English
主な活動
- Chambers Global Practice Guides – Corporate Tax 2024: Korea Chapter (Co-authored)
- Income Classification of the Payment for Overseas Software, Law Review Vol. 14, 2024 (Co-authored)
- Walk in the tax law (Pakyoungsa, 2022)
- Key Issues of Tax Law II (Pakyoungsa, 2021)
- Flaws in Certificate of Origin and Application of Conventional Tariffs under a Free Trade Agreement Vol. 37 No. 1 (2021)
- Taxpayer in Trust Under Trust Law, Seoul Tax Law Review Vol. 26 No. 1 (2020)
- Historical Study on the Structure of International Tax Law and Measures for Improvement, Journal of IFA Korea Vol. 36-2 (2020)
- Key Issues of the Foreign Financial Account Reporting Regime and Measures to Improve, International Tax Review Vol. 1 (2020)
- Constitutional Protection of Marriage and the Housing Tax System, Local Tax Review Vol. 7 No. 3 (2020)
- Taxation Issue of Real Estate Trust in Local Tax Law, BFL Vol. 94 (2019)
- Chambers Global Practice Guides – Corporate Tax 2019: Korea Chapter (Co-authored)
- Chambers Global Practice Guides – Corporate Tax 2018: Korea Chapter (Co-authored)
- Meaning and Basis of Judgment on “Place of Effective Management” under the Corporate Income Tax Law of Korea (JKL Vol. 17 No. 2, 2018)
- Improvement Plan of Withholding Tax System About International Transactions, Journal of IFA Korea Vol. 34-3 (2018)
- Key Issues of Tax Law (Pakyoungsa, 2016)
- Interpretation of Categorized Comprehensive Tax Law Clauses and the Limits Thereof, BFL Vol. 57 (2013)
- The Relationship Between Original Assessment and Subsequent Corrective Assessment Increasing Taxable Income, Case Study on Public Administration Vol. 16-1 (2011)
- Overseas Holding Company and Taxation, Seoul Tax Law Review Vol. 15 No. 2 (2009)
- International Inheritance Taxation and Inheritance Tax Treaty, Seoul Tax Law Review Vol. 13 No. 3 (2007)
- Reasonable Cause for Exemption of Penalty Tax and Interpretation of Tax Law, Special Law Review Vol. 8 (2006)
- Legal Structure of Tax Avoidance by Retaining Income Overseas, Seoul Tax Law Review Vol. 11 No. 2 (2005)
- A Study on Taxation of Controlled Foreign Corporations Doctoral Dissertation, Seoul National University (2005)
- Waiver and Gift Taxation of Subscription Rights, Seoul Tax Law Review Vol. 3 (1997)
- Key States’ Capital Gains Taxation on Stocks, Seoul Tax Law Review Vol. 1 (1995)
- A Study on Capital Gains Tax on Stocks, Yonsei University Master Thesis (1995)
- A Study on the Concept and Scope of Capital Gain Taxation, Seoul National University Master Thesis (1994)
受賞経歴
- 2019President's Commendation
- 2018IFA Korea Tax Scholar Award
- 2013Prime Minister's Commendation
- 2009Tax Law Association Junior Scholar Award
外部評価
- "Leading Individual" for Tax, Chambers Asia, 2013-2024 (Band 1)
- "Leading Lawyer" for Corporate Tax, Who's Who Legal, 2019-2024
- "Elite Practitioner" for Tax, Asialaw Profiles, 2020, 2023-2024
- "Leading Individual" for Tax, Legal500, 2024
- "Highly Regarded, Leading Adviser" for Tax Controversy, ITR World Tax, 2022-2025
- "Leading Lawyer" for Tax, Legal Times, 2022-2023
- "Best Lawyer" for Tax and Customs, JoongAng Ilbo, Korea In-house Counsel Association, 2023
- "Power Advisor" for Inheritance, Hankyung Money, 2023
- "Leading Lawyer" for Tax, Asialaw Profiles, 2017-2018, 2021-2022
- "Best Lawyer" for Tax, Lawtimes, 2022
- "Best Lawyer" for Tax and Customs, Hankyung Business, 2022
- "Litigation Star" for Tax, Benchmark Litigation Asia-Pacific, 2020-2021
- "Client Choice Awards" for Tax, Lexology, 2020
メディア
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ニュースレター ２０２２年税制改編および下半期における税務調査の方向性
2022.08.24 -
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2022.05.02