logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울행정법원 2014.06.17 2013구합58443
증여세부과처분취소
Text

1. The Defendant’s gift tax amounting to KRW 3,097,143,250 for the Plaintiff on May 9, 2012, KRW 842,543,810 for the gift tax of KRW 3,097,143,250 for the Plaintiff.

Reasons

1. Details of the disposition;

A. B (hereinafter “B”) is a KOSDAQ-listed corporation that runs software development and supply business, fashion business, etc., and the Plaintiff was a joint representative director B with C.

B. On December 23, 2008, B issued a bearer overseas private equity bonds with the total face value of USD 20,000,000,000,000,000 as follows. A non-permanent equity bonds with warrants (hereinafter referred to as “bonds with warrants on December 23, 2008”), which is an overseas investment-specialized fund, non-resident loan for non-resident capital fund (Vicis Cital Capital Gun, hereinafter referred to as “non-resident”) is a partnership partnership (hereinafter referred to as agent) LLC, which is a representative.

Through this, on December 23, 2008, the entire face value of bonds with warrants issued from the date of issuance: USD 20,000 (27,146,000,000, 1,357.30): the date of issuance of bonds: the maturity rate on December 23, 2008: 1.65% (5%) per annum on December 23, 2013 (8.5%) - The holders may claim early redemption of all or part of the principal amount of the bonds from the date one year has passed from the date of issuance of the bonds - the exercising rate of 10,100,000,00 (1,357,000: 1,350,000: 1,000,000,000: 20,000,000,000,000: 3,000,000,000,000

C. B repaid USD 15 million among bonds with warrants dated 23, 2008 to non-sis in response to the early reimbursement claim by non-sis on October 16, 2009.

On the other hand, non-sis requested to B on November 3, 2009 for early redemption of USD 5 million among bonds with warrants as of December 23, 2008, and USD 2 million out of USD 5 million which was unredeemed, B, the plaintiff and non-sis made early redemption of USD 2 million among USD 5 million which was unredeemed, and USD 3 million.

arrow