A. 1) The Plaintiff (former Life Insurance Co., Ltd.): (a) Nos. 4, 5, and 6 (hereinafter “each of the instant funds”) of the parent stand real estate investment fund, a limited partnership established under the laws of the United States Deteawa State, (MMMMMMM Gun International-T, L.P.) (hereinafter “each of the instant funds”).

Each of the instant funds was invested in the U.S.A. Limited Liability Company (hereinafter “LCC”) and each of the instant funds and each of the instant LCC is referred to, “the instant investment schemes” if they are referred to in both the Fund and each of the instant LCC.

A) A specific purpose company (TMK) established in Japan through a multi-level trading structure, such as the multi-level trading structure, etc. (TMK) is a specific purpose company established in Japan.

(2) The investment structure of each of the instant funds is almost the same, and the investment structure referred to in subparagraph (6) of this paragraph is as follows: (a) the investment structure of each of the instant funds was invested in various TMF, including Chofu Hering TMF; and (b) each TMF has invested in Japan by acquiring real estate in Japan.

Plaintiff

msREF VI International-T, L.P. (Dela certification) REF REFI TMK Investmentst LLC (De Certification) MAF REF RELF RELFLLC (Deho Regulation) Chofu TRK TBI in Real Estrate

B. Each TMK, such as Chofu Holding TMK, paid dividend income to the LLC that is a shareholder, such as SREF REFI Chofuold LLC, withholding corporate tax on the dividend income as the income earner, and paying it to the Japanese National Tax Service.

The LC and its superior LLC and the limited partnership did not select the corporate taxation method in the United States, which is the place of establishment, and did not pay corporate tax. As a result, the foreign tax credit was not applied to the tax amount withheld in Japan.

C. The plaintiff filed a corporate tax return for the business year 2005 (from April 1, 2005 to March 31, 2006), for the business year 2006 (from April 1, 2006 to March 31, 2007), and for the business year 2007 (from March 31, 2007 to March 31, 2008), and applied the foreign tax credit for each of the funds of this case to include expenses in deductible expenses. Each of the funds of this case shall withhold and pay it in Japan.