New Business Opportunities in Japan for Overseas Asset Managers 2023

30+ years experience in the financial industry. Played a leading role in the success of more than 100 domestic and cross-border M&A transactions in a wide range of industries. Maintains an extensive network of senior relationships with major Japanese corporations and financial sponsors. 

Prior to joining PwC in January 2020, he was Vice Chairman of Global Banking of HSBC. Prior to that, he spent 5 years at GCA Corporation, a Tokyo Stock Exchange listed independent M&A boutique, as a Managing Director. Earlier, he worked at UBS Securities for 7 years where he became Managing Director and Head of Mergers and Acquisitions and Financial Sponsor Group in 2011. 

His earlier experiences include working at Knox & Co., a US investment banking boutique, and at Montgomery & Co., an allied investment banking firm with Mitsubishi Tokyo Financial Group. He started his career at the Bank Of Tokyo in 1989.

Satoshi is qualified as a Japanese Certified Public Accountant and a Licensed Tax Advisor of Japan.
He has assisted global PE houses and their serviced funds’ Japanese portfolio companies for the last 15 years in various aspects such as fund raising, deal sourcing, technical diligence, structuring, PMI reorganization, other value creation, refinancing, exit structuring and tax audit defense. He has spent almost 100% of his time for serving global PE houses. He has also been in touch closely with global PE houses’ headquarter tax management team together with PwC US team for each deal and portfolio company ensuring the most tax-efficient structure from Japanese portfolio companies up the chains to ultimate investors from a US and Japanese tax perspective.

He joined PwC Tax Japan, Tokyo office in 2000 and has worked as a core member of the Transaction/M&A Practice Department (now, Private Equity OU). In that capacity, he has advised various PE houses as well as private/public multinational corporations with regard to their investments into Japanese/foreign companies, as well as assisted such target companies (or portfolio companies post acquisition) in restructuring their global and or local operations from a perspective of both “up above” fund structuring and “down below” acquisition structuring. As a project leader, he brings more than 20 years of experience at PwC managing all aspects of tax due diligence, modeling, and structuring.

He also has been a member of the Financial Services Industry Practice Department and has served PE funds as well as multinational financial institutions and service companies, to provide fund structuring services as well as to assist them with their compliance and consultation requirements. He has also assisted his clients including global PE fund clients with their national tax audits including a long term of tax audit challenging permanent establishment, tax treaty eligibility, non-resident capital gains tax and other international tax areas for his global PE fund clients.

He was assigned to PricewaterhouseCoopers New York in the International Tax Services for a 2-year period from January 2011 to December 2012 and performed tax consulting/structuring services on US inbound transactions for various Japanese multinational clients and on US outbound transactions for various US multinational clients from a Japanese tax perspective.

He is a graduate of The University of Tokyo, where he majored in Economics before beginning his professional career in PwC.

Stuart is an international tax adviser with 30 years of Stuart is an international tax adviser with 30 years of experience covering banking, capital markets, investment management, private equity, insurance, real estate, infrastructure and transfer pricing matters for funds, portfolio companies and financial services clients.

Stuart advises major US, European, Asian and Japanese funds on investment structures, transactions and fund raising. He also regularly advises global institutional investors, including international pension funds, funds of funds and sovereign wealth funds, in relation to their Japanese portfolio investments and commercial joint ventures. Stuart advises on market entry strategies for financial services companies starting up or expanding in Japan, supports in-bound M&A transactions across a wide variety of sectors, leads tax due diligence teams and advises on investment acquisition and financing strategies. He has led multiple projects advising international consortiums on the privatization of Japanese airport concessions.

Stuart has held several Asia Pacific leadership positions from his base in Tokyo, including for many years acting as the tax leader for the private equity industry, and more recently for the insurance sector. Since 2021, Stuart has acted as the Asia Pacific tax leader for real estate, infrastructure and real assets. Stuart also acts as the Joint Chair for the ULI / PwC publication Emerging Trends in Real Estate – Asia Pacific.

Stuart is a lawyer qualified in both England and Australia, with degrees in economics (BEc) from Macquarie University and law (LLB) from the University of Sydney. Stuart attained a Master of Laws from the University of London as a postgraduate student where he was also a prize-winner in finance law subjects.

Before moving to Tokyo in 2003, Stuart worked in our firm’s London office for six years focusing on banking and capital markets. Previously he worked for offices in Hong Kong and Sydney.

Stuart has acted as an expert witness before the High Court of Hong Kong where his evidence was fully accepted in adversary proceedings on judgment and subsequently upheld by the Court of Appeal. Stuart writes and speaks regularly on Japanese tax law developments, and has undertaken many projects for Japanese government bodies, including the Ministry of Finance, the Financial Services Agency of Japan, and the Tokyo Metropolitan Government, supporting government and industry association (including AIMA and Tokyo’s FinCity) tax reform initiatives.

Keiko Shimizu is a partner at Nagashima Ohno & Tsunematsu. One of the focuses of her practice is securities and financial services regulations, and she advises asset management companies, securities brokers, banks and other financial institutions on corporate governance, regulatory and compliance matters. She advises clients on the formation, marketing and operation of various collective investment vehicles such as investment trusts, hedge funds, private equity funds and fund of funds. She assists various onshore and offshore funds sponsors in structuring and forming the funds. The fund structuring advice includes regulatory advice and she provides practical advice based on a wide range of experience in both onshore fund and offshore fund formations. She also handles a variety of corporate transactions and general corporate affairs, and she advises clients on data protection matters.

She earned an LL.B. from the University of Tokyo and an LL.M. from Columbia Law School. She is admitted to practice in Japan. She also worked as the Partner of Nagashima Ohno & Tsunematsu NY LLP from 2015 to 2018.