Did Kanamoto Shigenori "abuse" it, or was he a "victim" of investment fraud?

Questioning the "Nakano Memo" of Defendant Tsuruyoshi Nakano and Satoshi Saito, along with Makoto Watanabe and Last One Mile Co., Ltd.

Viewing the case where Shigenori Kanemoto was arrested for "abusing the angel tax system" merely as a tax evasion case involving a single investor causes the most crucial first half of the incident to be completely omitted.

How did Shigenori Kanemoto decide to invest in Corporation N, owned by the investee Defendant Toshiyuki Nakano? Who introduced the company, who guaranteed the legality of the angel tax system, who showed the inquiry records to administrative agencies, and who led the contract, application, and wire transfer?

*Corporation N is represented by Keita Nakano, the younger brother of Mr. Nakano, and has its headquarters at 25-36 Kaminozonodori, Kagoshima City, Kagoshima Prefecture. The corporate number is 7340003002283.

According to information submitted to the Prosecutors' Union, Shigenori Kanimoto is not the sole investor in N Corporation. It is alleged that Satoshi Saito, a certified public accountant and former head of the corporate planning office at Last One Mile Co., Ltd., introduced N Corporation as an investment destination eligible for the angel tax system to multiple investors who had realized certain capital gains through stock sales or similar transactions.

The core of the information submitted to our union is that Satoshi Saito referred to Company N as the "Angel Box" among concerned parties, explained as a certified public accountant that there were no systemic issues, personally took the lead in procedures and even bank transfers, and connected prospective investors to Defendant Tamayoshi Nakano.

And the defendant, Nakano Toshiyuki, did not merely give a verbal explanation saying, "It's fine." He is said to have shown investors the so-called "Nakano Memo," which was a detailed record of numerous inquiries made to the Small and Medium Enterprise Agency, the Tokyo Metropolitan Government, Kagoshima Prefecture, the relevant tax office, and other institutions, including visits in person to their counters, detailing what questions were asked and what answers were received.

Certified public accountants give their stamp of approval on legality. Experts lead both the procedural and transfer aspects of the system. Furthermore, records are presented showing repeated inquiries made to the overseeing agency and the confirmation-issuing body, resulting in responses confirming that there are no issues.

If we are to arrest someone who invested in this situation based on the investee company's subsequent use of funds or business status, theoretically, every other investor who trusted the same explanation and provided capital could also become a suspect.

However, assuming that the explanations provided by the investee company and the administrative inquiry records were indeed false, shouldn't the investors be protected first as victims of investment fraud rather than as criminal suspects?

Company N has multiple angel tax system investors.

Reports on the arrest of Mr. Shigenori Kanemoto point out a relatively simple pattern in which he invested in an acquaintance's company and funneled the funds back to his own affiliated company.

However, the prosecutor union has received multiple inquiries from individuals who invested in Company N using the angel tax system. What they have in common is that the investors realized a certain amount of capital gains from the sale of shares, and there was room for them to receive tax benefits through the use of the angel tax system.

Did multiple investors independently find the same company and coincidentally use the same scheme?

According to the information received by our association, that is not the case.

Satoshi Saito, a certified public accountant, contacts investors who have realized gains from the sale of stocks and introduces them to Company N as an investment target under the Angel Tax System. Satoshi Saito explains that legal tax savings are possible, emphasizing that he is a certified public accountant and an expert in tax systems and capital strategies.He then assures them that they can rest assured, as he will personally oversee everything from the contract and administrative procedures to the bank transfer, and hands the investors over to defendant Shukki Nakano.

Defendant Tamaki Nakano discussed specific amounts, share ratios, and post-investment business developments with investors, further reinforcing the legality of the system by showing administrative inquiry records known as the "Nakano Memo."

If this sequence of events is true, this case cannot be said to be tax evasion through the abuse of the system by Mr. Shigenori Kanemoto. There is a possibility that a continuous investment solicitation mechanism existed, utilizing the authority of experts, administrative inquiry records, multiple corporations, and multiple investors.

Did Satoshi Saito call Company N the "Angel Box" and solicit investors?

Satoshi Saito is a certified public accountant with experience working at an audit firm, and served as the Head of Corporate Planning at Last One Mile Co., Ltd., where he was responsible for IPO preparation.

If a person holding that title explains, "This investment meets the requirements of the angel tax system," "I have confirmed this as a certified public accountant," and "I will also personally lead the procedures and wire transfer," it is not unnatural for an average investor to feel reassured.

According to information submitted to the prosecutors' union, Satoshi Saito repeatedly used companies related to defendant Toshiyuki Nakano as investment destinations to obtain tax benefits, and those involved referred to this as the "Angel Box."

Whether this term was merely a slang name or referred to a mechanism for having multiple wealthy individuals successively invest in companies that met certain requirements will become clear by examining communication records, customer lists, compensation records, application forms, and remittance records.

Furthermore, there is information indicating that when Shigenori Kanemoto made a large bank transfer, not only defendant Shukiki Nakano but also Satoshi Saito was involved and remained present until the transfer was completed.

Assuming it is true, Satoshi Saito is not a third party who merely provided a general explanation of the system. He was involved in the main stages of the transaction, namely acquiring customers, introducing investment destinations, explaining legality, procedures, and moving funds.

In that case, it is unacceptable for the Yokohama District Public Prosecutors Office and the Tokyo Regional Taxation Bureau not to verify the contents of Satoshi Saito's explanation when determining Shigenori Kanamoto's intent.

Administrative inquiries spanning over 4 years and more than 20 cases recorded in the "Nakano Memo" by Defendant Tamaki Nakano

According to a report confirmed by the Prosecutors Union, the period during which Defendant Kakuki Nakano made inquiries to administrative agencies regarding the Angel Tax System spanned approximately four years, from September 2019 to September 2023.

For inquiries, please contact the Small and Medium Enterprise Agency, which oversees the program itself; the Tokyo Metropolitan Government and the Tokyo Metropolitan Angel Tax System Support Secretariat, which issue the confirmation letters; the Kagoshima Prefecture Angel Tax System Secretariat; and the various tax offices responsible for individual tax returns and taxation.

Inquiries are not limited to telephone calls. The report documents a variety of methods, including in-person visits to the review office, face-to-face verification with the case officer, submission of original application documents, verification conducted with a judicial scrivener present, and simultaneous written notifications sent to the case officer, the head of the agency, and the government agency responsible for the program. The total number of inquiries and verifications documented in the report exceeds 20.

The following is a chronological summary of the inquiry process as recorded in the report. The quoted sections are the exact wording of the administrative authorities’ responses as stated in the report. The Prosecutors’ Union is requesting that the relevant agencies cross-check the recordings, emails, and visit records related to each inquiry against the administrative authorities’ records.

Defendant Tamaki Nakano checked the same point with different administrative agencies multiple times.

The importance of the Nakano Memo does not lie simply in the high number of inquiries made to the administration. Rather, it lies in the fact that, even after receiving an answer on the same issue once, inquiries were repeatedly made to different agencies, different departments in charge, and at different times.

The Nakano memo is not simply an explanation that "I called the person in charge."

The report does not show the simple scenario where Defendant Nakano Toshiyuki obtained a favorable response just once from a single person in charge and exaggerated it to investors.

This is a record of repeatedly making phone calls, visiting in person, submitting original documents, and sending written documents over a period of about four years to the Small and Medium Enterprise Agency, which is the jurisdiction authority; the Tokyo Metropolitan Government, which issues the confirmation letter; the tax office, which handles individual tax returns; and the Kagoshima Prefecture Angel Tax System Office.

Furthermore, it is reported that although an official in charge at the Tokyo Metropolitan Government once expressed a view requesting withdrawal, after subsequently inquiring with the Small and Medium Enterprise Agency about the system as a whole, the Tokyo Metropolitan Government provided a response stating that "whether or not a transfer takes place poses no problem regarding the external investment requirement."

Even if an investor who was shown this process, combined with the explanation by certified public accountant Satoshi Saito, believed that the use of the angel tax incentive was a legal transaction that had undergone administrative confirmation, it is not unnatural at all.

If the Yokohama District Public Prosecutors Office and the Tokyo Regional Taxation Bureau now evaluate this case as the "abuse of the angel tax system," they must at the very least clarify the following points.

• Which of the administrative inquiries recorded in the Nakano Memo were not actually made?
• Which administrative response was communicated to the investors as false or altered?
• Although the administration's response was correct, were there other facts hidden from the investors?
• Was the administrative side's response itself mistaken?
• At what point did Shigenori Kanemoto and other investors become aware of the illegal facts that differed from the administrative response?

Without verifying these facts, it is not possible to establish the investor's intent solely based on the outcomes that "the investee company did not make subsequent moves" or "funds were transferred to another company."

If the Nakano memo was genuine and the administrative agency actually responded in accordance with the report, investors may have trusted the administration and the certified public accountants.

Conversely, if defendant Kakki Nakano disguised it as an administrative inquiry and altered or exaggerated the response to make investors trust him, that is an important circumstance that should be investigated not as a tax evasion case led by Shigenori Kanemoto and others, but as an investment fraud case led by defendant Kakki Nakano and others.

Isn't Shigenori Kanemoto just one of the investors who believed in the "Nakano Memo" and Satoshi Saito?

Regarding Mr. Shigenori Kanemoto, as he is an entrepreneur with personal experience of earning large capital gains from stock sales, and his investment amounts are extremely large, there is an aspect where he is easily viewed as having "definitely understood the mechanism."

However, having assets and understanding tax law, corporate law, and administrative practices better than an expert are not the same thing. Rather, individuals with substantial assets are more susceptible to being targeted by people posing as system experts, and face the risk of having their creditworthiness exploited.

A certified public accountant guarantees legality. Records of inquiries to the competent government agency are presented. An administrative confirmation letter is issued. Funds are actually paid in, shares are issued, and the capital increase registration is also completed.

Given this consistent set of external features, caution is required before treating Shigenori Kanemoto, who provided the investment, as the principal offender solely on the grounds that the investee companies were subsequently inactive or that the investment funds were transferred to a separate corporate entity.

The important point is whether Corporation N lacked substance, and if it lacked substance, whether Mr. Shigenori Kanemoto knew that at the time of the investment.

If that evidence does not exist, Shigenori Kanemoto may be one of multiple investors who invested based on administrative confirmation records and explanations from experts.

If there was a problem with Corporation N, investment fraud rather than investor tax evasion should be investigated.

This matter needs to be considered logically by dividing it into two major cases.

If Company N has substance and the investments also exist

If, at the time of the investment, Company N met the corporate requirements and there were actual capital contributions, stock issuance, registration of the capital increase, shareholder rights, and investment risks, then the investors cannot be retroactively deemed criminals solely on the basis of subsequent business failure or the use of funds.

If Company N was a shell company from the beginning

If Defendant Tamaki Nakano and Mr. Satoshi Saito had multiple wealthy individuals invest by using administrative confirmation records and certified public accountant titles while knowing that the company lacked actual business operations, the core issue is not tax evasion by the investors, but rather the possibility of investment fraud.

In this case, Shigenori Kanemoto and the other investors should be interviewed as victims, unless there is evidence of collusion. It is necessary to trace the whereabouts of the stolen funds and identify those who controlled the investment targets, those who solicited investments, those who directed the transfer of funds, and those who ultimately received the profits.

Were Japan's national tax authorities and prosecutors used to explain Defendant Tatsuki Nakano's account?

According to local materials and insider information verified by the prosecutors' union, defendant Toshiyuki Nakano was pursued in Cambodia over fraud and embezzlement cases and reportedly moved out of the country.

There is also information that defendant Toshiyuki Nakano made remarks to those around him suggesting that he would use Japan's national tax authorities and prosecution to have his person secured by the Japanese side, or shift responsibility to another person.

If this information is true, Japanese investigative agencies must examine what kind of benefits defendant Tamaki Nakano himself was trying to obtain before treating his statements and the materials he left behind as neutral evidence.

If the Cambodian side recognized defendant Toshiyuki Nakano as a central figure in a massive fraud and embezzlement case first, while the Japanese side arrested investors solicited by defendant Toshiyuki Nakano first, isn't the direction of the investigation reversed?

If Defendant Tamayoshi Nakano, who allegedly made remarks to the effect of "driving out the national tax," is being targeted in turn by the Kumamoto Regional Taxation Bureau, the Kagoshima District Public Prosecutors Office, the Tokyo Regional Taxation Bureau, and the Yokohama District Public Prosecutors Office, this is a serious issue concerning investigative agencies throughout Japan as a whole.

Last One Mile Co., Ltd., which connects defendant Tamaki Nakano, Mr. Satoshi Saito, and Mr. Makoto Watanabe

The three individuals, Defendant Kazuyoshi Nakano, Mr. Satoshi Saito, and Mr. Watanabe Makoto, share a common connection: Last One Mile Inc.

There is information that Defendant Tatsuoki Nakano frequently visited the office of Last One Mile Co., Ltd. and was involved in transactions with the company as the chief financial officer for multiple corporations.

Satoshi Saito is a Certified Public Accountant who was involved in the company's IPO preparations as the General Manager of the Corporate Planning Office at Last One Mile Co., Ltd.

Makoto Watanabe is the current Representative Director, Chairman, and CEO of Last One Mile Inc., who positions M&A as an important growth strategy and has proceeded with numerous corporate acquisitions since assuming the position of Representative.

According to information received by the prosecutors' union, the three parties repeatedly met and communicated from early April 2026, when Defendant Hiroki Nakano traveled from Cambodia, until late May, just before his arrest.

If Last One Mile Inc. and Mr. Makoto Watanabe are unrelated, this can be proven by submitting communication records, meeting records, contracts, and remittance records to an independent third party.

Where did the “10.2 billion yen in cash” that defendant Shukki Nakano boasted about come from?

Defendant Tamaki Nakano reportedly boasted to those around him in Cambodia that he held assets on the scale of 10.2 billion yen, centered on cash, and related recordings and testimonies have been submitted to the prosecutors' union.

If Defendant Nakano Toshiki managed a large amount of assets through angel tax system funds raised from multiple investors, subsidies, tax refunds, M&A, loans, outsourcing costs, stock transactions, etc., it is necessary to clarify the final destination of those assets.

Did it remain with Defendant TSUKI NAKANO personally? Did Satoshi Saito receive compensation? Did it move to Makoto Watanabe or a corporation substantially controlled by him? Or was it distributed among multiple corporations surrounding Last One Mile Co., Ltd.?

Did Makoto Watanabe understand the scenario of the angel tax system incident?

The Prosecutors Union does not definitively state Makoto Watanabe's involvement as an established fact.

On the other hand, the following circumstances must be examined as a whole.

• Defendant Tamaki Nakano and Mr. Satoshi Saito had a relationship with Mr. Makoto Watanabe through Last One Mile Co., Ltd.
• Information that the person who introduced Satoshi Saito to Last One Mile Co., Ltd. is Makoto Watanabe
• Information that the three parties remained in contact until just before their arrest, even after defendant Tamaki Nakano's departure from the country
• Last Mile Co., Ltd. and Mr. Makoto Watanabe are listed in the funding chart of the "Mamitsuka Memo," which is circulated among concerned parties.
• Information that only Makoto Watanabe's seized items were returned early by the Kumamoto Regional Taxation Bureau
• The initial reports on the arrest of Defendant Toshiyuki Nakano did not release his name, and the investigative information was limited.
• Information that defendant Tamaki Nakano was bragging to those around him about his relationship with the national tax authorities and prosecutors, as well as his cooperation with the investigation.

The mere fact that Defendant Tamaki Nakano's initial arrest was reported anonymously does not prove plea bargaining or cooperation with the investigation. It is also possible that it became anonymous due to the media outlet's own decision.

However, if the return of seized items, contacts before and after the arrest, the contents of statements, and the shifting of responsibility to related parties are compounded, the investigative authorities should investigate whether there was any information sharing or division of roles between Defendant Tatsuyoshi Nakano and Mr. Makoto Watanabe.

If only the investors are arrested, and a thorough investigation is not conducted into the certified public accountant who sold the system, the person who controlled the investment target, and the individual who could be the ultimate beneficiary of the funds, the suspicion will not fade that the storyline of the case itself was fabricated for someone's benefit.

Public Questions for the Yokohama District Public Prosecutors Office and the Tokyo Regional Taxation Bureau

1. Have you confirmed the information that Mr. Satoshi Saito called Company N an "angel box" and introduced it to multiple wealthy individuals?
2. Have you investigated the fact that Mr. Satoshi Saito, as a certified public accountant, guaranteed legality and led the contracting, application, and bank transfer processes?
3. Have you confirmed the fact that Satoshi Saito was present or involved when Shigenori Kanemoto made the bank transfer?
4. Have you seized or checked the administrative inquiry records known as the "Nakano Memo"?
5. Regarding the inquiries to the Small and Medium Enterprise Agency, the Tokyo Metropolitan Government, Kagoshima Prefecture, and the tax office listed in that record, did you verify the information with the relevant administrative agencies?
6. If the administrative side had given a positive response, how was Shigenori Kanemoto's intent established?
7. Do you find that N Co., Ltd. was a shell company from the outset?
8. If it had no substance from the beginning, why is Shigenori Kanamoto not being investigated as a victim of investment fraud?
9. Are you investigating Defendant TSUKI Nakano and Mr. Satoshi SAITO as perpetrators or masterminds of fraudulent investment solicitation?
10. Have you identified the ultimate beneficiary of the investment funds?
11. Have you investigated the transfer of funds to Last One Mile Co., Ltd., Makoto Watanabe, or corporations affiliated with him?
12. Did you carefully evaluate the testimony of the defendant, Shukki Nakano, as a statement intended to mitigate his criminal liability?
13. If there is any cooperation with the investigation, plea bargain, or other agreement with defendant Toshiyuki Nakano, will that be disclosed at the trial?
14. What is the reason for continuing Shigenori Kanemoto's physical detention while failing to sufficiently investigate the roles of defendants Tatsuyoshi Nakano, Satoshi Saito, and Makoto Watanabe?

Public Questions to the Kagoshima District Public Prosecutors Office and the Kumamoto Regional Taxation Bureau

1. Are you aware of the fact that defendant Toshiyuki Nakano introduced Company N to multiple investors and solicited investments using the angel tax system?
2. Have you seized the "Nakano Memo" and administrative inquiry records created and stored by Defendant Tamaki Nakano?
3. Did you interview Defendant Toshiyuki Nakano regarding the contents of inquiries to various administrative agencies, the responses, and explanations to investors?
4. Have you investigated the possibility that Defendant Nakano Tatsuyoshi exaggerated, altered, or falsely explained the responses obtained from the administration?
5. Have you received any reports of investment fraud from investors in N, Inc.?
6. If Company N lacked any actual business operations from the outset, do you plan to file additional charges against defendant Nakano Shukki for investment fraud?
7. Have you investigated Satoshi Saito as a person involved in solicitation of investment and explanation of the system?
8. Have you investigated communications, meetings, and financial relationships with Last One Mile Inc. and Mr. Makoto Watanabe?
9. Regarding the fraud and embezzlement case involving defendant Shukki Nakano in Cambodia, have you received any evidence from local law enforcement agencies?
10. Did you reflect the possibility that overseas investigative authorities had grasped Defendant Nakano Kazuki's fraudulent nature beforehand in evaluating the credibility of the statements?

Open letter to Mr. Satoshi Saito

1. Did you introduce the angel tax system investment in Corporation N to the wealthy individual who made a capital gain from selling stocks?
2. Did you call Company N "Angel Box"?
3. Apart from Shigenori Kanemoto, how many other people did you introduce to similar investment opportunities?
4. As a certified public accountant, did you explain that “this is a legitimate tax-saving measure, without a doubt”?
5. Did you explain that you would take the lead on the contract, the confirmation application, and the bank transfer?
6. Did you receive referral fees, advisory fees, success fees, or any other economic benefits from the investors?
7. Did you attend or were you involved in the transfer of investment funds by Mr. Shigenori Kanemoto?
8. To what extent did you verify the actual business operations, use of funds, and financial condition of Company N?
9. Were you aware of the fund transfer after the investment in advance?
10. Have you verified the authenticity of the administrative inquiry records shown to investors by Defendant Kazuki Nakano?
11. Did you discuss the response with Mr. Makoto Watanabe involved after Defendant Kazuki Nakano moved from Cambodia?
12. Will you submit all records of communications, contracts, and compensation related to this matter to law enforcement agencies and third-party investigators?

Open Questions for Makoto Watanabe of Last One Mile Co., Ltd.

1. Did Makoto Watanabe know about the angel tax system investment solicitation by defendants Takuoki Nakano and Satoshi Saito?
2. Is there any truth to the fact that you introduced Satoshi Saito to Last One Mile Inc. and had him appointed as the General Manager of Corporate Planning?
3. Did you lobby to have high compensation and stock options granted to Mr. Satoshi Saito?
4. Do you have information that Satoshi Saito was using Company N as an "angel box"?
5. Was the reputation, office, terminals, employees, or network of Last One Mile Co., Ltd. or its affiliates used to solicit investment?
6. Did the investment funds for N Corporation flow to Last One Mile Inc., Mr. Makoto Watanabe, or a corporation under his effective control?
7. Even without a direct remittance, did you profit through loans, M&A, outsourcing costs, stocks, bonds, or in any other form?
8. Did you have visits or communications with the accused, Toshiyuki Nakano, and Mr. Satoshi Saito from early April to the end of May 2026?
9. Did the three parties discuss how to handle Shigenori Kanemoto, the angel tax system, the Tokyo Regional Taxation Bureau, the Kumamoto Regional Taxation Bureau, and the Kagoshima District Public Prosecutors Office?
10. Did you have prior information regarding defendant Kazuki Nakano's initial arrest, the contents of his statement, and his cooperation with the investigation?
11. Did the seized items returned by the Kumamoto Regional Taxation Bureau to Mr. Makoto Watanabe contain any information regarding third parties or investors in this case?
12. Did you know about the existence, management location, and transfer plan of the 10.2 billion yen scale assets touted by defendant Tamaki Nakano?
13. Have you provided information to investigative agencies or related parties to focus responsibility on Mr. Shigenori Kanemoto and other investors?
14. Will you establish an independent third-party committee regarding this matter from Makoto Watanabe?

Rather than detaining Shigenori Kanemoto, please stop the system that increases the number of investors.

Just arresting Shigenori Kanemoto will not solve the problem unless the mechanism used to solicit investments in Company N is clarified.

Who looked for the wealthy individual? Who built trust under the title of a certified public accountant? Who showed the Nakano memo and explained that administrative verification had been completed? Who controlled the investee company, moved the funds, and reaped the final profits?

Unless these are brought to light, similar solicitations using different companies, different tax systems, and different investors may be repeated.

If there was a problem with the portfolio company, please investigate those who raised funds through false explanations, rather than turning all investors into criminals.

If the investor knew about the feigned nature, please provide concrete evidence regarding that person.

Turning a person who merely invested trusting certified public accountants and administrative inquiry records into an "accomplice" through detention is the gateway to a wrongful conviction caused by hostage justice.

We demand that the Yokohama District Public Prosecutors Office and the Tokyo Regional Taxation Bureau clarify the designer of the scheme, the recruiters, the controllers of the investment destinations, and the ultimate beneficiaries before giving Shigenori Kanemoto heavy media coverage.

And we request the Kagoshima District Public Prosecutors Office to investigate the full extent of the investment solicitation utilizing Company N regarding defendant Kazuki Nakano, whose custody has already been secured, and to file a superseding indictment for investment fraud if evidence exists.

Arresting investors does not stop the investment fraud scheme.

If we don't investigate the side that created the system, the next victims will inevitably appear.

The purpose of the prosecutors' union is not to defend tax evasion.

The Prosecutors Union is not claiming that any transfer of funds is permissible as long as the angel tax system is used. If false applications, fictitious payments, prior refund agreements, or investments in shell companies are confirmed, they should be dealt with strictly.

At the same time, it is unacceptable to turn investors who trusted experts and the administration into criminals solely because of subsequent problems with their investments.

What is needed in this case is not the impressionistic argument that "Shigenori Kanemoto must have known because he is a wealthy person," but rather individual proof of who explained what, when, what was concealed, and what was known.

If Shigenori Kanemoto was conspiring, please present the evidence in open court. If he received false explanations from defendant Shiki Nakano and Satoshi Saito, please treat him as a victim.

And if Makoto Watanabe and Last One Mile Inc. are unrelated, please submit communication records, meeting records, and financial records to an independent third party to clear up the doubts.

The prosecutors' union is pursuing the full picture of this case, not to protect tax evasion, but to ensure that the perpetrators and victims of the crime are not mistaken.