A. In around 194, the Plaintiff acquired a master’s degree in semiconductor field at a U.S. B school in 1994, and obtained a doctor’s degree in semiconductor field at a U.S. C university in 2000.

The Plaintiff worked in D, a semiconductor company, from around 2000 to October 2008, and was employed in the semiconductor general management unit of E Co., Ltd. (hereinafter “E”) around November 2008 and worked in the above business division, etc. until September 2016.

B. In around 2005, the Plaintiff acquired U.S. permanent residency by maintaining the nationality of the Republic of Korea. Accordingly, E, a withholding agent for the Plaintiff’s earned income, constitutes “foreign engineer” subject to special exemption from income tax pursuant to the Restriction of Special Taxation Act (hereinafter “Special Act”), and did not perform the Plaintiff’s duty to withhold tax on the earned income accrued in the year 201 through 2013.

C. In the process of examining the details of the year-end tax reduction and exemption for E’s year 2011 through year 2015, the head of the same orchard Tax Office: (a) found the Plaintiff, a worker with Korean nationality, to be a foreign engineer under the Special Act on the Regulation, and found the Plaintiff’s failure to perform the withholding obligation for the tax withholding on the wage and salary income for the year 201 through year 2013; and (b) notified the Defendant.

Accordingly, on April 1, 2017, the Defendant imposed the global income tax of KRW 172,631,270 (including penalty tax of KRW 15,693,752) for the year 201, and imposed the global income tax of KRW 158,132,140 (including penalty tax of KRW 48,826,729) for the year 2012 and global income tax of KRW 118,891,763 (including penalty tax of KRW 30,023,433) for the year 2013.

E. On August 21, 2017, the Plaintiff filed an appeal with the Tax Tribunal regarding each of the above dispositions, and the Defendant revoked ex officio the penalty tax for failure to pay for the year 2011 while the appeal procedure is in progress.