The defendant written on March 2, 2017 (attached Form) with respect to the plaintiff.

[1] The plaintiff was born in the Republic of Korea in 1953 and was married with B in 1979 and lived in the United States from that time.

On September 25, 1990, the Plaintiff and B acquired 1/2 shares in USD 1,750,017 for each of the instant housing units H (G. APT H, Los Anges, CA, USA, hereinafter “instant housing”).

The plaintiff continued to live in the United States and acquired permanent residence in the United States in 2008.

[2] The Plaintiff donated 1/2 shares of the instant housing from October 10, 2012

(hereinafter “instant donation”). On October 10, 2012, the Plaintiff transferred the instant house to “I” at USD 4,000,000.

(hereinafter “instant transfer”). On March 2, 2017, the Defendant imposed a gift tax of KRW 1,074,120,299 (including additional tax of KRW 419,640,299) on the ground of the instant gift and transfer, as stated in the attached Form, on the ground of the gift and transfer, and imposed a disposition of imposition of capital gains tax of KRW 381,295,990 (including additional tax of KRW 198,643,176).

(2) The Plaintiff’s assertion (i) at the time of donation and transfer does not constitute a resident under the Inheritance Tax and Gift Tax Act and the Income Tax Act.

Therefore, the Plaintiff does not support the obligation to pay gift tax and transfer income tax on the gift and transfer of this case.

Luxembourg Even if the Plaintiff falls under a resident as prescribed by the Income Tax Act at the time of the transfer of the instant case, the Plaintiff also falls under a resident as prescribed by the U.S. law. However, the Plaintiff’s assertion of Article 3(2) of the Convention between the Republic of Korea and the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect