Seoul High Court 2013Nu25773 ( December 13, 2013)

(C) the fact that the general share swap is deemed a new title trust because it constitutes a onerous transfer.

(B) It is reasonable to view that the general share swap constitutes a commercial transfer, and thus, cannot be deemed a substitute or modified product of the previous shares, and the trustee has an intention to maintain a title trust relationship with respect to new shares newly allocated to him/her.

2014Du1512 Revocation of Disposition of Imposition of Gift Tax

United Kingdom A

The director of the tax office.

Seoul High Court Decision 2012Nu25462 Decided February 7, 2013

Supreme Court Decision 2013Du5791 Decided August 23, 2013

Seoul High Court Decision 2013Nu25773 Decided December 13, 2013

The appeal is dismissed.

The costs of appeal are assessed against the Plaintiff.

The judgment of the court below and the appellate brief all of the records of this case, but the appellant's ground of appeal is not included in the grounds provided by each subparagraph of Article 4 (1) of the Act on Special Cases Concerning the Procedure of Appeal or it is recognized that there is no reason. Thus, the appeal is dismissed under Article 5 of the same Act. It is so decided as per Disposition by