1. The Defendant reverted to the Plaintiff on April 1, 2014 the global income tax of KRW 486,843,310, and the global income tax of KRW 2009.

1. Details of the disposition;

A. During the period from 2008 to 2011, the Plaintiff received KRW 4,471,348,00 from a limited liability company (BCO., LIMFD, hereinafter “ Hong Kong”) located in Hong Kong as its representative, KRW 867,410,50 in 208, KRW 841,154,70 in 209, KRW 619,603,300 in 2010, KRW 2,151,079, KRW 500 in total, KRW 4,471,348,00 in total.

B. As a result of conducting a tax investigation against the Plaintiff, the director of the Central District Tax Office: (a) deemed that the Plaintiff was a domestic resident under the former Income Tax Act (amended by Act No. 12852, Dec. 23, 2014; hereinafter the same) and notified the Defendant by deeming that the said dividend income was omitted.

C. Accordingly, on April 1, 2014, the Defendant decided and notified the Plaintiff of the total global income tax of KRW 2,238,584,414 (including additional tax) as follows.

The determined tax amount to be reverted to the year of accrual of the determined tax amount to be reverted, 2008 486,843,310 291,321,754 2009 439,310,553 2011,021,021, 108,797 aggregate 2,238,584,414

D. The Plaintiff appealed and filed an appeal with the Tax Tribunal on June 19, 2014, but was dismissed on December 24, 2014.

[Ground of recognition] Facts without dispute, Gap evidence Nos. 1 through 3, Eul evidence No. 1, Eul evidence No. 14, Eul's whole purport of pleading

2. Whether the disposition is lawful;

A. In light of the following: (a) the Plaintiff’s summary of the Plaintiff’s assertion 1 left Korea with his family in around 2004 and resided in China on June 23, 2004 while operating the Hong Kong corporation, a holding company, and thereafter investing in the establishment of a Chinese corporation, and (b) paid income tax in China in relation to wage income; and (c) the period during which the Plaintiff was staying in Korea is merely the period of May 3, 2008, July 70, 2009, October 101, 201, and January 161, 201, the Plaintiff is not a “resident” under the former Income Tax Act, and thus, is obligated to pay comprehensive income tax under the former Income Tax Act.