A. The Plaintiff’s status D Co., Ltd. (the first one was the E Co., Ltd., which was changed to the current trade name on October 27, 2008; hereinafter “D”) is a company that owns Seoul F, G land (hereinafter “instant land”) and three underground floors above and ten floors above the ground and buildings above the ground (hereinafter “instant building”) and operates real estate leasing business, etc. together with the instant land.

The plaintiff (the father of H, who is the representative director of D) held office as the representative director of D until October 12, 201, and 47,520 shares of D (79.2%) out of 60,000 shares issued by D as of October 12, 201, the plaintiff held the remaining 12,480 shares (20.8%) respectively.

B. Around May 2008, the Plaintiff anticipated that the gift of the instant real estate to its children would be subject to a tax of about 40 billion won when the Plaintiff donated the instant real estate to its children, and requested the J to prepare a plan for tax saving. The J along with K and L, as a certified public accountant, donated the instant real estate to its children without paying taxes (hereinafter “the gift”).

The plaintiff planned and proposed to the plaintiff, and the plaintiff accepted and implemented the plan, and the details of the franchise are as follows.

In other words, in the Republic of Korea, when the gift tax base exceeds KRW 3 billion, about 50% tax shall be paid for the excess portion, but Hong Kong shall not impose income tax or gift tax on stock transfer, taking advantage of the fact that D obtained a loan of KRW 30 billion from the bank as security of the instant real estate from the bank and made an investment in the Chinese Steel Company through Hong Kong Pucomer in Hong Kong, but it is pretend that D would have made an investment in the instant real estate after several months, and as such, recovered KRW 4.5 billion out of the said funds as settlement money, and the remaining amount shall be set up in Hong Kong as a foreign corporation.