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(영문) 대전지방법원 2017.01.12 2016구합100613
증여세부과처분취소
Text

1. The Defendant’s gift tax for the Plaintiff on July 6, 2015 KRW 1,747,406,570 on the gift tax for the year 2009, and the gift tax for the year 2010 3,487.

Reasons

1. Details of the disposition;

A. The status of the parties 1) B Co., Ltd. (C Co., Ltd.) was changed from around March 2007.

“B” regardless of whether it is before or after the change;

(i) its own mining weapons (hereinafter referred to as the “Inorganic Weapons”) used as the light source, etc. of a mobile phone.

[2] A company specializing in the production and supply of goods was established on April 28, 199, and was listed on the KOSDAQ on October 25, 2007. 2) The Plaintiff served as a registration director of B from March 2007 to June 2014.

B. The Plaintiff’s exercise of the Plaintiff’s preemptive right in 2009 (1) B) on December 7, 2006, another securities company (hereinafter “new securities”)

After concluding a bond subscription contract with the company, on December 12, 2006, JY 370,000,000 (fixed Exchange Rate 800,38,000, 100, 100, 100, 1000) 1. Unguaranteed overseas private equity bonds (hereinafter “instant 1 bonds”).

The alternative securities were issued on the same day, and the entire 1st bonds of this case are ASIN BOND FUD II (CAYN) LIMFED (hereinafter referred to as “SPC”)

2) The SPC issued P-CBO (hereinafter “P-CBO”) securities subject to collateral security and sold them to overseas investors and the Small and Medium Business Corporation. The separated warrant certificates (hereinafter “First warrant certificates”) were sold to B, B, B’s representative director D and substitute securities.

3) On April 2, 2007, the Plaintiff acquired from B the total face value JPY 73,00,000,000 of the instant first PPY securities in KRW 72,705,000. On September 14, 2009, the Plaintiff acquired the instant first PPY securities (the exercise price of KRW 2,450 per share) and acquired KRW 238,480 per common share of B. C. The Plaintiff’s exercise of the preemptive right in 2010.

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