YOON&YANG

• Tax
• Tax Advisory ∙ Tax Strategy
• Pre-Audit Diagnosis ∙ Tax Audit
• Tax Trial
• Tax Litigation
• International Taxation ∙ Transfer Pricing
• Criminal Defense
• Tax Compliance ∙ Outsourcing
• Corporate Succession
• Customs Investigation ∙ Customs Audit
• Customs Appeal ∙ Authoritative Interpretation
• Transfer Pricing
• Tariff Classification Advisory
• Trusts
• Real Estate Trust
• International Tax Strategy Center

• 2016-present Yoon & Yang LLC
• 2026-present Legal Counsel, Korea Electric Power Corporation (KEPCO)
• 2025-present Research Director, International Fiscal Association Korea
• 2023-present Director, Tax Future Forum
• 2013-present Researcher, Korea University Center for Tax Law and Policy
• 2022-23 Vice Chair, Korea Tax Association Future Society
• 2021-22 Vice Chair, International Tax Association YIN Korea Branch
• 2020-21 Internal Auditor, Local Tax Future Forum
• 2019-20 Member, Youth Committee, Korea Local Tax Association
• 2010-13 Certified Public Accountant, Samil PriceWaterhouseCoopers (International Tax / Global Services)

• 2022 Duke University School of Law (LL.M.)
• 2019 Korea University Graduate School of Law (Ph.D. in Law, Certificate of Completion)
• 2016 Korea University School of Law (J.D.)
• 2011 Korea University (B.A. in Business Administration)

• Admitted to bar, Korea (2016)
• Certified Tax Accountant, Korea (2012)
• Certified Public Accountant, Korea (2010)

Tax Controversy & Litigation

• Leads tax advisory practice representing domestic and foreign corporations, shareholders, and executives in tax audits, administrative proceedings, and correction claim filings across a broad range of tax matters.
• Leads representation of real estate trust companies in trust-related tax disputes; secured reversal of corporate income tax assessments in administrative and judicial proceedings; and manages related civil and criminal exposure.
• Represents executives of multinational enterprises and major domestic corporations in criminal tax proceedings, including investigations and trials involving allegations of tax evasion.
• Represents blockchain companies and digital asset exchanges in tax audit defense; leads accounting and tax advisory mandates in connection with virtual asset transactions.
• Secured reversal of corporate income tax, tobacco consumption tax, and individual consumption tax assessments imposed on a leading multinational tobacco company.
• Secured reversal of gift tax assessments arising from the transfer of seabed mining rights.
• Secured reversal of corporate income tax and gift tax assessments relating to a publicly listed company's issuance of convertible bonds and bonds with warrants.
• Led litigation challenging local tax and related assessments concerning real estate investment funds managed by a Korean asset management company.

International Tax & Cross-Border Transactions

• Leads advisory mandates for multinational corporations on the strategic implications of, and responses to, the OECD Pillars framework.
• Leads outbound M&A tax engagements involving foreign portfolio companies and counsels on cross-border tax planning strategies.
• Leads advisory on stock-for-stock exchange transactions involving Korean corporations in connection with U.S. listings and corporate redomiciliation.
• Leads tax and civil litigation involving intercompany royalty arrangements—including trademark and patent licensing fees—within major Korean corporate groups.
• Counsels Korean companies with U.S. investments on the Inflation Reduction Act (IRA) and the One Big Beautiful Bill Act (OBBBA) and on available tax credits.
• Represented clients in U.S. bankruptcy proceedings and counsels on the tax treatment of bad debt deductions relating to domestic receivables.
• Led VAT refund and withholding tax correction claim filings and counsels on international tax matters for a global biotech company.

• Notable Practitioner, International Tax Review (ITR) (2026)
• YIN Award, International Fiscal Association Korea (2019)

[Books]

• A Study on Policy Factors Supporting Tax Administration: A Legal Analysis of the Issues and Improvement Measures of the Adjustment Request System under the Framework Act on National Taxes – Korea Institute of Public Finance (Co-author, 2023)
• Tax Practice Study II - Yoon & Yang LLC (Co-Author, 2018)
• Criminal Law on Foreign Exchange, Korea Customs and Trade Development Association (Co-Author, 2017)

[Academic Papers]

• South Korea Chapter, Trends and Developments, Investing In..., Chambers Global Practice Guides, Chambers and Partners (Co-author, 2026)
• South Korea Chapter, Transfer Pricing, Chambers Global Practice Guides, Chambers and Partners (Co-author, 2025-2026)
• South Korea Chapter, Tax Controversy, Chambers Global Practice Guides, Chambers and Partners (Co-author, 2024-2025)
• The Compensated Nature of Real Estate Acquisition in Corporate Spin-Offs, Study on Special Law, Vol. 21, Supreme Court Special Litigation Practice Research Association (2025)
• Review on the 2020 Supreme Court’s Decisions Related to the Value-Added Tax Act and Customs Act, Vol. 27, no. 1, Seoul Tax Law Review, Tax Law Association (2021)
• Issues from the Decrease in Executable Properties and Tax Evasion Using Trusts - Focusing on the Value Added Taxes in Real Estate Trusts -, Vol. 26, no. 3, Seoul Tax Law Review, Tax Law Association (2020)
• Restitution in Integrum through the Contract Rescission & Acquisition Tax, Vol. 323, CPA Monthly (2020)
• Commentary of Tax Cases, KICPA Press (Co-Author, 2020)
• Study on Disposal of Income and Withholding Tax on Outflow of Income by Transfer Pricing Taxation, Vol. 35-3, Journal of IFA, International Fiscal Association Korea Press (2019)
• Beneficial Ownership under the Tax Treaty, Tax Practical Research, vol. 2, Yoon & Yang Tax Group (2017)
• The Scope of Related Parties in Korean Tax Law and Study of Systematic Reform, vol.14, Korea University Law Review (2013)