1. The Defendant’s gift tax (including additional tax) imposed on Plaintiff A on January 19, 2017, limited to KRW 140,131,040, and the Plaintiff B on June 27, 2018.

1. Details of the disposition;

A. The plaintiff A(C) and B (D) left the Republic of Korea with E (the mother of the plaintiff) around July 1994.

The plaintiffs and E acquired permanent residency in the United States on October 17, 1996.

B. On April 19, 2006, E purchased land located in the Republic of Korea Veneson (F; hereinafter “instant land”) in the U.S. 1,140,000, and registered 1/3 in the name of E and G (C) respectively in the name of E and the Plaintiffs.

C. On January 19, 2017, the Defendant deemed that E, a domestic resident, donated funds for acquiring the instant land to the Plaintiffs, a domestic resident, and imposed KRW 140,131,040, and KRW 139,614,200 on the Plaintiff A on June 27, 2018, by deeming that the Defendant donated a gift tax (including additional tax) to the Plaintiff on July 5, 2018.

The head of Samsung Tax Office imposed gift tax on Plaintiff B on January 18, 2017, but revoked ex officio on the ground of lack of jurisdiction during the instant lawsuit, and the Defendant imposed gift tax on Plaintiff B on June 27, 2018.

(See 3, 4 pages of the preparatory brief dated July 5, 2018). / [Grounds for recognition] A without dispute, entry of evidence Nos. 1, 3 through 6, B 1, 13, 14, 15, and the purport of the whole pleadings.

2. The attachment to the relevant Acts and subordinate statutes shall be as follows;

3. Whether the instant disposition is lawful

A. Summary of the party’s assertion 1) Plaintiffs’ Inheritance Tax and Gift Tax Act (hereinafter “Inheritance Tax Act”)

A) In the event that a non-resident donated property located in a foreign country to a non-resident, both a donor and a donee do not have a gift tax liability. Even if a donor is a resident, a donee, who is a non-resident, does not have a gift tax liability. The Plaintiffs are both non-resident and non-resident. Even if a donor is a resident, the Plaintiffs are non-resident, and thus, there is no gift tax liability. (2) Defendant E is clear that the Plaintiff is a domestic resident, and the Plaintiffs were also residents at the time of acquiring the instant land.