---
title: "International and cross-border taxation — overview"
url: https://memocore.ai/memos/6a5f63e663d783ad687094bc
project: "Doing Business in Japan"
tags: "tax-sole-proprietor, japan-business"
updated_at: "2026-07-21T12:19:50.228Z"
---

# International and cross-border taxation — overview

Japan residents with foreign assets, companies, or income face an additional layer of tax rules. Topics covered: CFC (Controlled Foreign Company) rules; offshore companies and undistributed dividends; the 5-year/remittance rule for non-permanent residents; the difference between ordinary PR and tax PR status; treatment of a US LLC as a pass-through entity; remittance tax on transfers into Japan; scrutiny of the origin of large transfers; the legal risk of a "gift" scheme; the Common Reporting Standard (CRS); the concept of a permanent establishment; withholding for foreign contractors; taxation of foreign salary with no Japanese employer; currency accounting at the TTM rate; invoice requirements for foreign counterparties; and restrictions on transferring large sums to Russia. See the linked detail records for each topic.