Mr. Jae Young PARK is one of the firm’s leading experts in the field of tax law at D&A LLC. His practice is primarily focused on National Tax & Local Taxation, Tax Litigation, Representation in Tax Investigations, and Administrative Procedure & Litigation.

¦ Extensive Insight Built on a Decade of Hands-On Experience at the National Tax Service
Since his official appointment to the National Tax Service in 2012 as a Grade-5 officer through a special recruitment program for experienced professionals, Mr. Park held key positions within the agency for over a decade until his retirement in 2023. Rather than limiting himself to short-term external consulting or an observer’s role, he built unwavering expertise through years of direct involvement in tax administration and policy as a career public official.

Having served in a wide range of key roles, including Senior Team Leader for Inheritance and Gift Tax Litigation at Investigation Bureau 3 and the Litigation Bureau of the NTS Seoul Regional Tax Office, the Tax Collection and Legal Affairs Bureau of the National Tax Service, Taxpayer Advocacy Bureau of the Seocho District Tax Office, and the Tax Collection and Legal Affairs Bureau of the Jungbu Regional Tax Office, he acquired an in-depth understanding of the internal mechanisms and decision-making logic of tax authorities, earning a reputation as a true insider and expert on the National Tax Service.

¦ Leading Authority on Inheritance and Gift Tax Investigations and Assessments
In particular, during his four-year tenure at Investigation Bureau 3 of the Seoul Regional Tax Office, the division responsible for inheritance and gift tax investigations involving high-net-worth individuals, Mr. Park led the development of core taxation theories and investigative strategies. He played a pivotal role in identifying increasingly sophisticated tax evasion schemes and developing corresponding enforcement logic. He also personally drafted internal investigation manuals for the National Tax Service and helped disseminate advanced investigative techniques throughout the organization.

It is no exaggeration to say that many of the major tax issues currently attracting attention among high-net-worth individuals have undergone Mr. Park’s thorough review and analysis.

? Real Estate and Valuation Issues: Appraisal of small commercial buildings; gift tax arising from increases in property value after acquisition
? Stock and Capital Transaction Issues: Gift tax arising from stock conversions involving convertible bonds (CBs); gift tax arising from transactions involving specified corporations, mergers, and IPOs; deemed dividends involving spousal shareholding arrangements
? Core Inheritance and Gift Tax Issues: Family business succession deductions and spousal inheritance deductions; deemed gifts arising from nominee arrangements; loans between related parties and disallowance of unfair transactions

¦ Widely Recognized Tax Expert by Both Tax Authorities and Industry
Mr. Park serves as an adjunct professor at the National Tax Service, delivering over 100 hours of lectures annually on tax practice to tax officials and external organizations. He has earned deep trust within the National Tax Service through his clear analytical approach and practical, action-oriented solutions.

In addition, having served for seven years as a member of the Seoul Regional Tax Office’s Advisory Committee on Taxable Fact Determinations, which deliberates on key issues arising during tax investigations and makes final decisions regarding tax assessments, he possesses unique insight encompassing both the perspective of tax authorities and the position of taxpayers.

Bar Admissions

• Admitted to Bar, Korea (2010)
• Certified Financial Risk Manager (2003)
• Securities Investment Adviser, Futures Trading Advisor (2002)

Education

• Yonsei University Law School (LLM in Tax Law, 2020)
• Yonsei University (BA in Economics and Minor in Law, 2002)
• Seonggwang High School (1994)

Significant Accomplishments

• D&A LLC (2023-Present)
• Full Member, Academic Society for Administrative Law and the Rule of Law (2017-Present)
• Adjunct Professor, National Tax Officials Training Institute, National Tax Service (2015-Present)
• Head of the Investigation Bureau III, Seoul Regional Tax Office (2020-2023)
• Member, Advisory Committee on Taxable Fact Determinations, Seoul Regional Tax Office (2017-2023)
• Member, National Tax Review Committee and Taxpayer Advocacy Committee, Seocho District Tax Office (2019-2020)
• Director, Taxpayer Advocacy Bureau, Seocho District Tax Office (2019-2020)
• Chief Head of the Inheritance and Gift Tax Litigation Bureau, Seoul Regional Tax Office (2017-2019)
• Head of the Tax Collection and Legal Affairs Bureau, National Tax Service (2015-2017)
• Member, Advisory Committee on Taxable Fact Determinations, Jungbu Regional Tax Office (2013-1014)
• Section Chief of the Tax Collection and Legal Affairs Bureau, Jungbu Regional Tax Office (2012-2015)
• Judicial Research and Training Institute of the Supreme Court of Korea (2010)
• Civil Mediation Commissioner, Seoul Central District Court (2009)

Professional Activities and Experience

• 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

• Sales Allowances and Mileage System Under the Value-Added Tax Act (2018)
• Limitations of Imposition of Gift Tax on Stock Held in Secondary Nominee Name (2018)
• Guarantor’s Withholding Tax Obligation to Foreign Corporations (2017)