Gary M. Thomas concentrates on international tax planning and tax controversies. He is registered as a Japanese zeirishi (licensed tax attorney), fully qualified to practice before the National Tax Agency (NTA) and the National Tax Tribunal, the only US tax lawyer with such qualifications. He has worked in Japan for over 25 years and is fluent in spoken and written Japanese.  Mr. Thomas also is a member of the California Bar and the Illinois Bar and is registered in Japan as a gaikokuho jimu bengoshi. 

Mr. Thomas advises US, European, Japanese and other companies in connection with tax planning and defense and resolution of tax controversies in audits, domestic appeals, and government-to-government consultations under applicable tax treaties.  He is well known as an expert in transfer-pricing planning and documentation, audits, competent authority procedures and advance pricing arrangements (APAs) involving Japan.  He also has handled cases involving permanent establishment issues for foreign firms.

In addition, he provides advice concerning US and Japanese tax law and international tax treaties for various transactions involving Japan, including M&A, joint ventures, partnerships, and inbound and outbound investments.

From 2000 through 2002, Mr. Thomas was the Chair of the Taxation Committee of the American Chamber of Commerce in Japan (ACCJ).  He was deeply involved in the effort to encourage the US and Japan to negotiate a new US/Japan income tax treaty, which was finally ratified in March 2004.  He also served as the principal ACCJ representative on a tax task force established with the Japan Chamber of Commerce that in 2000 issued recommendations for improving the Japanese tax system to facilitate international business.

He served as instructor in the advanced international tax course at Japan’s National Tax College, the in-house training institute of the NTA, and lectured on international tax treaties at the International Seminar for Taxation in Asian Countries (ISTAC), a training institute operated by the NTA for foreign tax officials.

Mr. Thomas has written and lectured extensively (in both Japanese and English) on transfer pricing, international tax planning, and dispute resolution.  He is the author of the Japanese transfer-pricing chapter in BNA Tax Management’s Foreign Income Portfolio series.

He received his Bachelor of Arts in Political Science and Japanese Language from the University of Washington in 1973, his law degree from Harvard Law School in 1977, and Master’s degrees in law (taxation) and business administration (accounting) from Asia University, Tokyo.