April 15, 2026
Kumamoto Regional Taxation Bureau
Director Atsushi Kitamura
Investigation and Inspection Department, Inspection Division 3
To: Go Shimazaki, Former Supervising Inspector
Former Chair Nobuhiro Kawaguchi
Chief Examiner Hiroshi Oka, Ph.D.
Inspector Keisuke Ota
Tokyo Regional Tax Office
Inspection Division, Inspection Department 21
Hideto Nakamura, Lead Examiner
Global Union (National Tax Union)
All union members
Web:https://globalunion-grp.org/okami/
Demand for In-Person Investigation — As an Exercise of Constitutional Rights
Dear Sir or Madam, I hope this message finds you well.
As the Global Union / National Tax Union, exercising the right to organize and the right to act collectively guaranteed by Article 28 of the Constitution, we hereby formally request an in-person investigation as follows.
No. 0: About Our Union—The World’s First Union with No Dues and the Universal Declaration of Human Rights
1. Relief Measures, Including Those Who Work Part-Time or in the Informal Sector, with No Union Dues
Our union is the world’s first initiative established as a “dues-free union” that does not collect any union dues. Even for business owners who work during their spare time on platforms such as Timee, we do not deny their status as workers if a de facto relationship of supervision and direction exists, and our union actively provides relief (Article 9 of the Labor Standards Act).
Going forward, our communications will not be limited to mail; we will operate the following website as the official primary point of contact for the union. Your office is obligated to accept and respond to notifications, requests, and requests for responses submitted via the website as having the same legal effect as those submitted in writing.
2. The Declaration as an International Human Rights Issue That Goes Beyond Japanese Standards
Our union is not bound by standards limited to Japan. A majority of our members are foreign nationals whose stock ownership and other rights have been denied by your agency, and this matter—as an issue that denies the human rights of many foreign nationals—will spread widely throughout the world in the future.The International Covenants on Human Rights (International Covenant on Civil and Political Rights, Article 26), ILO Conventions (Nos. 87 and 98), and constitutional guarantees of human rights in various countries will serve as international benchmarks for evaluating this matter.
3. Declaration on the Exercise of the Right to Organize and the Right to Collective Action Using the Latest Technology
Our union goes beyond mere discussions at the level of the General Rules Law, positioning this as an issue of constitutional and human rights. We will deploy an exercise of the right to organize and the right to collective action at a level that transcends the limits of imagination, combining real-time minutes generation by AI, immediate written documentation of all records, blockchain-based tamper-proof evidence preservation, simultaneous mobilization of 200,000 people via social media, coordination with international union networks, strategic utilization of media coverage, and simultaneous complaints to labor boards and human rights agencies in various countries. It is simply unimaginable that a single administrative statute like the National Tax General Rules Law would function in the face of such ultra-powerful union activities. The scope of the rights guaranteed by Article 28 of the Constitution expands infinitely with the evolution of technology.
Part 1: Underlying Facts
1. The Worsening of Union Members’ Mental Illnesses—The “Evidence Gap” Caused by a Failed Data Migration and the Invalidation of the Inspection Findings
As of now, at least 15 of our union members have been diagnosed with mental illnesses, and the symptoms of many members are becoming more severe. Each member’s physician has repeatedly stated the medical opinion that “direct contact, whether in person or by phone, significantly worsens their symptoms.” Regarding union members, including ●●●●, we had been informed in detail—via the “Mamizuka Memo” from tax accountant Mamizuka—that your agency might obtain another search warrant and conduct another seizure without sharing the more than 100 explanatory documents with the court. Therefore, assuming that your agency has already verified this information through the seizure proceedings in question, we have already submitted the medical certificates.Nevertheless, is it correct to understand that Mr. Oka and Mr. Ota of your agency have once again failed to seize the medical certificate in question?
Furthermore, the impact of these repeated demands for in-person interviews extends beyond the individuals mentioned above; it has spread to other union members and related parties, causing anxiety, stress, sleep disorders, and difficulties in performing their duties. Consequently, this matter is not an isolated issue but has taken on the characteristics of systemic and cascading health hazards.
At this point, there is a critical fact that must be reiterated: the fact that Chief Investigator Hiroshi Oka, while openly speaking with Mr. ●●●● on the phone, had absolutely no knowledge of the status of the submission of the medical certificate regarding his mental illness. This was not a case of accidental ignorance.During the execution of the warrant on January 13, Reiwa 8, your bureau seized Mr. ●●●●’s cell phone; this is further evidence that you once again failed to transfer the data.
Mr. ●●’s cell phone contained communication records detailing the union members’ mental health conditions, the circumstances surrounding the submission of medical certificates, and the doctors’ instructions.However, as a result of a failed data transfer, your agency was unable to obtain this information, and Mr. Oka continued his telephone communications without being aware of the basic fact that “the medical certificate had already been submitted.” This constitutes a violation of the fundamental principles of digital forensics (integrity and continuity of evidence).
There is a more fundamental issue. Your agency failed to transfer data from a cell phone at the very beginning of the inspection (during the initial response phase under Director Shimazaki), and has repeated the same failure with Mr. ●●’s cell phone in this case.The “Chain of Custody”—a fundamental principle of digital forensics ensuring the identity and continuity of evidence—has been broken twice, from the initial response through to the present.
This fact fundamentally undermines the legality and validity of the inspection investigation. The intent of Articles 218 and 222 of the Code of Criminal Procedure and the Act on the Enforcement of the National Tax Offenses Act is to require that findings of fact be made only after ensuring the integrity and authenticity of the evidence and providing the opportunity for questioning and rebuttal.Since the continuity of the evidence has been severed from the very outset, all subsequent investigative procedures lack a valid evidentiary basis and are deemed substantively invalid. Given that the tax audit has lost its evidentiary value due to two failed data transfers, requesting a face-to-face investigation amounts to nothing more than a continuation of an invalid procedure.
2. Illegal statements by Chairperson Hiroshi Oka (directed by Bureau Chief Kitamura)
Under the direction of Director Atsushi Kitamura, Chief Hiroshi Oka officially stated that the union would “continue to request in-person interviews” with union members who have been medically diagnosed with mental disorders (as recorded in telephone records from January and March of Reiwa 8).
3. The Expansion of Secondary Harm Resulting from Remarks by Chairperson Hideto Nakamura
Hidetoshi Nakamura, a senior inspector with the Tokyo Regional Tax Bureau’s Audit Division, informed Mr. ●●●●—who was neither a subject of the investigation nor a witness—that “we will conduct a face-to-face interview,” and also stated that “we have information on 250,000 union members.”As a result of this chain of events, 15 union members are currently receiving social security benefits (workers’ compensation, sickness and injury allowances, and disability pensions).
4. New harassment issues arising from forced in-person surveys of corporate representatives (workers)
Your office takes the position that "only the person in charge will be sent to face-to-face investigations." However, this creates an unacceptable problem for our union. Going forward, when representative directors of various corporations respond to your office's face-to-face investigations, it is inevitable that they will mirror your position and order employees, such as accounting staff, to attend the face-to-face investigations as a work directive. In other words, by demonstrating an operation to the effect that "only the person in charge will handle face-to-face investigations," it can be said that a practical handling limiting the entity responding to investigations to the staff level has been formed by your office's own judgment.
In this regard, with respect to the parties entitled to exercise the right to request information and conduct inspections under the General Rules of National Taxes Act, there is no provision limiting such rights to representatives—whether on the part of administrative agencies or corporations—and it is generally understood that these rights should be exercised flexibly against any person capable of providing relevant facts.
Therefore, since your agency has adopted an operational approach that assumes direct contact with designated personnel, there are no systemic restrictions preventing the corporation from similarly opting for contact at the designated personnel level; this structure of interaction should be regarded as a consequence resulting from your agency’s operational practices.
Based on the foregoing, we believe that the decision to have the on-site investigation in this case conducted by a team composed of staff at the operational level was based on your agency’s operational judgment, and that your agency itself should provide a consistent explanation of the consequences of that decision.
In this case, the following problems arise in a chain reaction. First, harassment by employers toward employees stemming from the content, pressure, and prolonged detention associated with in-person audits (in cases where the content of work orders infringes on the employee’s personal rights).Second, the intimidating behavior, persistent questioning, and psychological pressure directed by National Tax Agency officials toward corporate representatives (employees) give rise to issues equivalent to customer harassment.It is self-evident that when employees—who are in a weaker position than business owners—attend in-person audits, their psychological resilience is lower, and their risk of developing mental health disorders is higher than that of business owners.
From the perspective of preventing such structural harassment, our union demands that—since your agency permits the framework of “conducting in-person investigations with corporate representatives (workers)”—you mandate measures to protect workers’ mental health during such proceedings (ensuring the presence of a lawyer, providing advance notice of the duration, providing reasonable accommodations for those with mental health conditions, andconducting harassment prevention training) to protect the mental health of workers during such interviews. As a labor union, this is a legitimate demand to protect our members.
5. It has become difficult to continue working as usual due to repeated demands for in-person interviews and psychological pressure.
The issue at hand in this case is that a combination of factors—including a request for an in-person interview, demands for a response, the failure to return seized items, and statements and actions suggesting future adverse consequences—collectively imposed a burden on an individual who was already experiencing mental distress, to the extent that it could not be medically overlooked.
Our union members have reached a point where it is difficult for them to continue making decisions, interacting with others, and performing their duties as usual.
This condition is not merely a matter of subjective anxiety, but rather a substantive health issue consistent with a physician’s diagnosis and determination of work restrictions. Therefore, this case should be addressed as an issue closely related to the inability to perform work, leave of absence, and social insurance benefits.
Nevertheless, continuing to require in-person contact without first fully exhausting less invasive alternatives—such as written communication, handling matters through a representative, or limited telephone verification as necessary—may hinder the individual’s recovery and could result in further harm to their health.
Part 2: Regulations of the Act on General Rules for National Taxes and the Structure of the "Unrestricted On-site Inspection Authority"
The authority to conduct questioning and inspections, as provided for in Article 74-2 et seq. of the General Rules of the National Tax Act, imposes no restrictions whatsoever on the method of investigation (in person, in writing, or by telephone). Precisely because the General Rules of the National Tax Act imposes no such restrictions, the Constitution—as the supreme law—must serve as a check on it. This case is not a matter of interpreting the General Rules of the National Tax Act, but rather an issue that requires a constitutional resolution.
Section 3: Violations of Numerous Rights Guaranteed by the Constitution: Grounds Beyond the General Provisions Act
1. Property rights (Article 29 of the Constitution)
The union member's property (computers, business card cases, mobile phones, passports, credit cards, etc.) has been detained for a long period, and the return is being delayed without even allowing questions. This violates the guarantee of property rights under Article 29 of the Constitution.
Despite the confirmation of multiple fraudulent uses of the seized credit card, no formal written response has been provided. We raise a serious issue in this regard in light of the following facts:
First, as the organization that produced the Mamizuka Memo, which leaked a massive amount of investigative information, it has already been proven that your bureau's information management system has fundamental flaws. Second, Supervisor Tsuyoshi Shimazaki stated that "the GSE files cannot be found," admitting himself that the management of seized items is not thorough. In such an organization, asserting that the seized credit cards were "properly stored" is an irresponsible claim that sweeps your lack of information management capability under the rug.
Hideto Nakamura, a chief inspector at the Tokyo Regional Taxation Bureau, has asserted that "fraudulent use cannot occur," but such a definitive statement is a textbook example of fragile thinking that lacks consistency with the reality of information management within the organization. Given that this is an organization that leaked top-secret investigative information known as the Mamizuka Memo to the outside, and where Supervising Director Shimazaki cannot even ascertain the location of the files, there is no logical basis for asserting that fraudulent credit card use "cannot occur."
Furthermore, despite the fact that regarding the management of seized items, Chief Examiner Hiroshi Oka "bears the obligation to respond as a matter separate from the investigation" (the principle of administrative accountability), he did nothing more than give abstract responses such as "they were stored appropriately," and completely failed to provide specific answers fulfilling his legal duty of explanation, such as specific management records, logs of entries and exits, identification of persons with access rights, and the names of management supervisors. This is proof of incompetence in failing to fulfill the duty of explanation and serves as a basis for establishing negligence in a state redress claim.
2. Freedom of Life and Person (Articles 13 and 31 of the Constitution)
Continuing forced contact despite the repeated submission of psychiatric medical certificates violates both Articles 13 and 31 of the Constitution. In some cases, "dolus eventualis" (constructive intent) may be established.
3 Freedom of residence, movement, and travel (Article 22 of the Constitution)
The seizure of a passport directly restricts the freedom to travel abroad guaranteed by Article 22 of the Constitution. Coercive contact at the airport, persistent coercion to return to the country, and the sharing of entry information with customs create a significant chilling effect on the freedom of movement. The understanding that the attachment of a court-issued seizure warrant allows for the seizure of any and all property without limitation must be said to lack a fundamental understanding of the purpose and limits of the seizure system.
In seizures conducted in accordance with criminal procedures, the principles of specificity of the objects based on a warrant, necessity, and proportionality are strictly required. Particularly for important items directly related to an individual's freedom of movement and property rights, such as passports and credit cards, whether they can be seized and how they are managed fall under categories that demand the most careful judgment and a high standard of duty of care.
Nevertheless, if a situation has been reached where, after the seizure of the property in question, no questioning or inspection has been conducted regarding the related factual circumstances, yet suspicions of unauthorized use are being pointed out, it must be evaluated not merely as a procedural defect, but as containing serious problems concerning the core of the system in both the assessment of the necessity of the seizure and the subsequent management structure.
Given the gravity of the responsibilities associated with the heavy public power of seizure and the importance of its proper administration, such a situation cannot be overlooked, and your bureau is strongly urged to fulfill its accountability in a concrete and verifiable manner regarding the legality of the seizure and the actual state of its management.
4. Right to Honor / Social Reputation (Article 13 of the Constitution)
It has been confirmed that the representative referred to union members as "tax evasion contractors" and "B-account specialists." Actual harm has been caused to the listed-company-related corporation due to coercive contact at Fukuoka Airport, and the infringement of the right to honor is specific and severe.
5 Due Process of Law (Articles 31 and 35 of the Constitution)
The Supreme Court Grand Bench ruling of July 1, 1992 (Narita New Law Case) recognizes that the guarantee of due process extends to administrative procedures as well. The structure of this case, in which a policy of "prosecution is unavoidable" is unilaterally notified without presenting the issues, providing an opportunity for rebuttal, or disclosing the evidentiary structure, is a textbook example of a violation of due process.
6. Right to Privacy and Protection of Personal Information (Article 13 of the Constitution)
Chief Examiner Hideto Nakamura stated that he "holds the information of 250,000 union members." Our members' personal information is managed on overseas servers and is extremely difficult to obtain without formal procedures (such as MLAT). There is a suspicion that it was acquired through illegal means, and your bureau has the responsibility to explain the acquisition route.
7. The Three Fundamental Rights of Labor (Article 28 of the Constitution) - The Direct Basis of This Demand
The three labor rights under Article 28 of the Constitution are guaranteed even against the state (Supreme Court Grand Bench Decision of October 26, 1966, "Zentei Tokyo Central Post Office Incident"). Our union demanding an in-person investigation as an organization is the legitimate exercise of rights under Article 28 of the Constitution, and any interference is a violation of the same Article.
Section 4: Risk of National Bankruptcy and Administrative Rationality
The continuation of inspection investigations driving union members into mental illness and leading to social security benefits places a serious adverse burden on the national treasury. Since compensation is limited to 60 to 80 percent of salaries, it ultimately leads to claims for state redress. Furthermore, if cases increase where corporate representatives (workers) contract mental illness during face-to-face investigations, the scale of social security benefits will expand exponentially. Early resolution is the only rational choice to minimize the impact on the national treasury.
V. Problems regarding information holding indicated by the Mamitsuka memo and questions regarding the route of personal information acquisition
1. What "The national tax authorities are aware of most things" means and●●Connection to the seizure of Mr./Ms. [Name]'s mobile phone
The Mamizuka memo includes the definitive statement that "the National Tax Agency has grasped almost everything." It is presumed that the actual status of our union member as a recent worker was also grasped due to the seizure of Mr./Ms. ●●'s mobile phone during the execution of the warrant in January 2028. However, since that information has not been accurately acquired due to a data migration failure, the premise of "having grasped it" has collapsed. This contradiction is the fundamental explanation for the fact that Chief Examiner Oka called without knowing about the existence of the medical certificate.
2 Questions regarding the acquisition route of the 250,000-member roster
Lead Inspector Hideto Nakamura stated that he "possesses the information of 250,000 union members." Much of our union members' personal information is managed on overseas servers and is extremely difficult to obtain through official procedures alone. There is a suspicion that it was acquired through methods other than official procedures (illegal means such as hacking), which raises issues regarding the application of the Act on Prohibition of Unauthorized Computer Access and Article 234-2 of the Penal Code, and your bureau has a responsibility to explain this.
3 The chain of information leakage indicated by the connection to the Mamizuka memo
The only reason tax accountant Mamizuka was able to provide detailed descriptions of the investigation progress, prosecutor consultation status, seizure warrant acquisition practices, and other such information is because information subject to the confidentiality obligation under Article 100 of the National Public Service Act was leaked by personnel of your office. Regarding the chain reaction of "information leak → Mamizuka memo → external dissemination → onset of mental illness in union members," your office cannot turn a blind eye to the contents of the seized memo.
Section 6 Utilization of the Information Provision System and Declaration of Union Activity
The National Tax Agency has published an information provision system on its website, and our union members and many related individuals will utilize this system from now on while sequentially requesting in-person investigations. As the National Tax Union, our union has already begun exercising the right to organize and the right to engage in concerted actions on the web, and will continue to center our union activities around requests for in-person investigations.
Section 7: Specific Requirements
1. Conduct an in-person investigation with Director Atsushi Kitamura (respond with a schedule by the end of April 2026)
2 Conduct of face-to-face investigations with Lead Inspector Hiroshi Oka and Inspector Keisuke Ota (same as above)
3. Conduct of face-to-face tax investigation with Hideto Nakamura, Inspector, Tokyo Regional Taxation Bureau (ditto)
4. Pursuit of the omission of never making a call despite acknowledging that "international calls are possible" and notice of a request for information disclosure
Chief Examiner Nobuhiro Kawaguchi stated that he "made a call but could not get through," and Chief Examiner Hiroshi Oka clearly acknowledged in phone calls on January 13 and March 12, 2026, that "it is possible for the Regional Taxation Bureau to call overseas" and "it is possible if permission is obtained" (recorded and transcribed using AI). Furthermore, he stated that "questions to a representative are also possible" and "written responses can also be handled as an administrative service."
However, both Mr. Kawaguchi and Mr. Oko have explicitly stated that they have "never once" spontaneously made international phone calls, and only reiterate "please conduct an in-person investigation" whenever we, the union members, call them. The conclusion logically and inevitably derived from this fact is as follows:
(i) The survey method is not limited to face-to-face interviews, and it is acknowledged that alternative means exist.
(ii) Insisting exclusively on in-person meetings while stating that alternatives exist is a clear violation of the principle of proportionality and the principle of least infringement.
(iii) The fact that they acknowledged international calls were possible but never made a single call proves a "lack of intent to ask questions." Requesting an in-person meeting despite having no intent to ask questions is nothing less than forcing an in-person meeting in a way that deviates from the purpose of the system.
(iv) In a situation where a medical certificate for a mental disorder has been submitted, continuing to demand only in-person interaction without ever using the less burdensome telephone is a complete abandonment of the obligation to provide reasonable accommodation under the Act for the Elimination of Discrimination against Persons with Disabilities.
(v) This passive and unassertive attitude of not even making a single phone call is an abandonment of the obligation of national public servants to devote themselves to their duties (Article 101 of the National Public Service Act).
More fundamentally, the attitude of "demanding an in-person investigation only when we, the union members, call" is not evaluated as a "sincere attempt at investigation" even in the context of a voluntary investigation. It is completely rational for a union member with a mental illness to conclude that "there are other methods, but seeing the National Tax Agency official who tries none of them, there is no reason, motivation, or obligation to return to Japan while suffering from a severe mental illness."
Furthermore, if there is no sincere response to this request, this union will, based on the Information Disclosure Act, request the disclosure of internal records, approval documents, and directive documents concerning the fact that Chief Examiner Kawaguchi and Chief Examiner Oka recognized that "telephone contact with overseas is possible." We will also request the disclosure of documents concerning the reasons for systematically avoiding the exercise of the authority to conduct questioning and inspection by telephone. Regarding any decision not to disclose, we will proceed with filing an objection with the Information Disclosure and Personal Information Protection Review Board and filing a lawsuit for revocation.
5 Written response regarding the feasibility and timing of the return of seized property (within 2 weeks)
6. Disclosure of acquisition route regarding Chairperson Hideto Nakamura's possession of 250,000 pieces of information (within 2 weeks)
(i) Specific legal basis and procedures for obtaining the information in question
(ii) Confirmation that methods other than official procedures were not used to obtain information stored on overseas servers
(iii) The schedule and timing for the disposal and deletion of such information
7. Written confirmation (within two weeks) as to whether or not Chairperson Hiroshi Oka's statement that "we will continue to request face-to-face surveys even for individuals with mental illnesses" was based on instructions from Director-General Kitamura.
8. Protection measures for corporate representatives (workers) (respond to the policy within two weeks)
Since your agency has adopted the framework of "conducting in-person investigations with corporate representatives," we demand that the following protective measures be implemented.
(i) Securing the attendance of a lawyer or union representative
(ii) Advance notification of required time and question content
(iii) Fulfillment of the obligation to provide reasonable accommodations for personnel with mental disorders
(iv) Clarification of attribution of responsibility in the event of harassment caused by in-person surveys
If a written response is not provided within the specified period in response to the above request, our union will implement (i) filing a lawsuit for state redress, (ii) filing a report with the Minister of Finance and the Minister of Internal Affairs and Communications, (iii) petitioning members of the National Diet, (iv) providing information to news agencies and international media, (v) consecutively applying for on-site inspection requests by additional union members, (vi) filing a disclosure request based on the Act on Access to Information Held by Organs of the Administration, and (vii) filing a report with the ILO and United Nations human rights bodies.
Above
[Additional Note: Invalidation of Inspection Investigations, International Human Rights Issues, and Technology Group Actions]
There is no restriction on face-to-face investigations under the General Rules for National Taxes inspection power, and criminal tax investigations can theoretically continue indefinitely. However, in this case, where the chain of custody has been broken by two data migration failures, the legal basis for the tax inspection has already collapsed. Eight constitutional rights—property rights, freedom of the person, freedom of travel, the right to reputation, due process of law, the right to privacy, the protection of personal information, and the three labor rights—stand opposed to a single administrative statute known as the General Rules for National Taxes.
Furthermore, our union is an international organization with numerous foreign union members whose ownership of shares and other rights have been denied by your bureau. This matter is not merely a tax issue for Japan alone, but a human rights issue for foreign nationals to which the International Covenants on Human Rights and ILO Conventions apply, and it will spread on a global scale. The right to organize and the right to collective action will be exercised on a dimension never even anticipated by the General Provisions, utilizing AI real-time minutes, blockchain evidence preservation, the mobilization of 200,000 social media users, and international union network cooperation. Through this document, we strongly demand that your bureau respond with full awareness that this will unfold at a level that transcends the limits of imagination.
Finally, on our union's "National Tax Union" website, we have properly organized and published related information, including the names of everyone involved in this matter. Moving forward, we intend to thoroughly pursue the unearthing of the truth until we reach a mutually satisfactory resolution.
Global Union
All union members
Web:https://globalunion-grp.org/okami/
