
By the time you reach Issue 06, you know what the problem is, what the solution looks like, and whether it applies to your situation. The one thing left is finding the right person to build it with. That part is harder than it sounds.
THE CREDENTIAL IS NOT THE QUALIFICATION
Japan has approximately 80,000 registered licensed tax accountants. Most of them are excellent at what they do. Almost none of them specialize in estate planning for high-net-worth foreign residents — and fewer still have designed the family holding company structure described in this series.
A credential tells you someone passed an exam. It tells you nothing about whether they have sat across from a US executive, understood the implications of a foreign holding company under US passive foreign investment company rules (PFIC — a US tax rule that applies to foreign corporations with predominantly passive income), called a contact at a regional bank to discuss financing for a non-Japanese director, and coordinated with a UK solicitor on domicile status — all for the same client.
"A tax accountant who has never worked with a foreign resident is not a specialist in this problem. They are a generalist encountering it for the first time."
WHAT THE TEAM ACTUALLY LOOKS LIKE
This is not a single-advisor problem. The structure described in Issues 02 and 03 requires at minimum three specialists working in coordination.
The first is a Japan-licensed tax accountant with specific experience in estate planning for foreign residents. They design the tax structure, run the valuations, handle the corporate documentation, and manage the ongoing compliance inside the holding company.
The second is a banking relationship — either a direct relationship with a regional bank officer willing to lend to a foreign-directed company, or an introducer who can open that door. Without this, the structure stalls at Step 2. No financing, no acquisition. No acquisition, no structure.
The third is legal support for corporate setup. In straightforward cases, your tax accountant will handle this through a working relationship with a legal scrivener — the specialist in Japan responsible for company and property registration. In more complex cases, you may need a dedicated attorney for the structuring itself.
For US, UK, and certain other nationalities, there is a fourth: a home-country qualified advisor who can review the Japan structure for compatibility with your domestic tax obligations. They do not need to be in Tokyo. They need to be willing to work with your Japanese team.
THE FIVE QUESTIONS
Bring these to the first meeting. The quality of the answers tells you everything.
"How many foreign resident clients have you helped with estate planning?"
Volume matters less than specificity. "Several" is not an answer. "Twelve over the past six years, mostly US and UK nationals, three of whom used the family holding company structure" is an answer. Press for specifics. Vague answers are data.
"Do you have experience working alongside advisors in my home country?"
An advisor who has never coordinated with a US estate attorney or UK solicitor on a shared client does not know what they do not know about the cross-border layer. This question separates advisors who think Japan-only from advisors who think about the full picture.
"Can you introduce me to a regional bank that would consider financing a holding company in this situation?"
This is the most revealing question in the list. Advisors with the right network give you a name. Advisors without one say "we can explore options." The structure depends on this introduction existing. If they cannot provide it, the plan cannot be executed regardless of how well it is designed on paper.
"What happens to the structure if I need to leave Japan unexpectedly?"
An advisor who has thought through exit scenarios has thought about the full lifecycle of the plan — not just the entry. An advisor who is surprised by the question has not.
"How do you charge for this work, and what does the engagement typically include in the first twelve months?"
A properly designed estate plan for a significant foreign resident estate involves specialist hours across multiple disciplines. If the fee quote feels low, something is being excluded. Understanding the full scope of the engagement before signing anything is essential.
THE RED FLAGS
Five signals that the advisor in front of you is not the right one for this work.
They do not ask about your nationality or home-country tax exposure in the first meeting. This is the most disqualifying signal. If they are not curious about your passport, they are not thinking about the cross-border layer that determines whether the Japan structure is complete or partial.
They say they can handle the entire engagement alone. The correct answer to the question of whether other specialists are needed is: yes, at minimum a banking relationship and possibly cross-border legal counsel. Anyone who says otherwise is either overconfident or underselling the complexity of the work.
They move to solutions before understanding your full situation. The first meeting of a proper engagement is almost entirely questions — asset composition, family structure, residency history, home-country obligations, timeline, risk tolerance. A specialist who skips this and goes directly to a recommendation has not gathered enough information to make one.
They have no banking relationships to offer. Ask directly. The answer reveals whether the structure they propose can actually be built.
They are unfamiliar with the family holding company structure described in this series. This is not a niche approach. It is a well-established, widely-used mechanism among families planning multi-generational wealth transfer in Japan. An advisor who has not encountered it in practice has a different client base than the one this series addresses.
THE TRAP
"I already have a tax accountant for my annual filing."
Annual tax compliance and multi-generational estate planning for a high-net-worth foreign resident are different disciplines. Your annual filing advisor may be excellent at what they do. That is not the question.
The question is whether they have designed this specific structure for a foreign resident, coordinated a banking introduction, managed the ongoing compliance inside a family holding company, and understood the cross-border implications of doing so. Most general-practice tax accountants have not — not because of lack of ability, but because it is not their area of practice.
The gaps will not appear in their advice. They will appear in the structure, years later, when they are expensive to correct.
"The wrong advisor does not give you bad advice. They give you incomplete advice — and you may not know what is missing until it is too late."
YOUR MOVE
You have read six issues. You understand the problem, the mechanism, the eligibility criteria, the cross-border complications, the cost of delay, and now the evaluation framework for finding the right team.
The one thing a newsletter cannot give you is the introduction itself.
Reply to this email with three things:
Your nationality. Your approximate asset level in Japan. Whether you have a child who could credibly serve as a company director.
I will respond within 48 hours with a specific recommendation — not a list of options, but a name: a tax accountant who has handled cases that match your profile, has the banking network the structure requires, and knows when to bring in a cross-border specialist.
That is the introduction this series has been building toward.
"Finding the right specialist is not more research. It is a conversation with someone who already knows who they are."
A NOTE ON SEASON 1
This is the final issue of Season 1. The six issues have covered the complete foundation: the exposure, the structure, the eligibility criteria, the cross-border complications, the cost of delay, and the team required to execute.
Season 2 will go deeper into execution — property selection for holding company assets, the ongoing compliance mechanics, restructuring options as family circumstances change, and the longer-term management of the structure once the planning horizon has passed.
If you want to be notified when Season 2 begins, reply with "Season 2."
This article is for informational purposes only and does not constitute tax, legal, or financial advice. The questions and evaluation criteria described are general guidance and do not substitute for professional due diligence specific to your situation. Please consult qualified advisors in each relevant jurisdiction before making any decisions.