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(영문) 서울행정법원 2015.05.28 2014구합73388
법인세부과처분취소
Text

1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

Reasons

1. Details of the disposition;

A. Lone Star Fund III established LF III REC III, L.P., L.C., LF III Bmeruda, L.P., respectively in Luxembourg, and each of the above corporations established Lux Euro-Euro-Assian Insur Ⅲ, S.L. Ⅲ, and S.L. under the Asset-Backed Securitization Act on June 30, 201, the said Lux Euro-Assurian Insur 3 and S.L. established the Plaintiff, a limited liability company specializing in asset-backed securitization under the Asset-Backed Securitization Act. 2) A (hereinafter “A”) was an asset management company specialized in asset management, and performed the Plaintiff’s business supervision, records of the Plaintiff’s business activities, the Plaintiff’s asset management company’s transfer, management, and disposal, etc., as prescribed by the Asset-Backed Securitization Act.

B. Lone Star Fund 1) Operational process of Lone Star Fund 1) Operational process of Lone Star niers, Lone Star Fund Operators, and LP Members C (hereinafter “C”) for the management of real estate and investment assets.

(D) and D (hereinafter referred to as “D”)

C) The E Co., Ltd. (hereinafter referred to as “E”) has been established and for the management of physical assets and investment assets in Korea.

(2) The executive officers of Lone Star Fund, such as insolvent financial institutions and the Korea Asset Management Corporation, have set up A, and D established A, and called a regional manager, dispatched Lone Star Fund to take charge of the business affairs of E and A. 2) E and E to take charge of the business affairs of Lone Star Fund. The executive officers of Lone Star Fund, who are in charge of the pertinent affairs, carried out the Originization business, carried out the business affairs of realizing assets to be invested in Korea, and after reviewing whether to make an investment by holding Rll-U Mtling and reporting the assets to the Investment Committee of Lone Star Head Office in the United States and making a decision to invest in the head office through auction.

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