Seoul Administrative Court 2010Guhap4429 ( October 30, 2011)

early 209west340 ( October 31, 2010)

Since the ownership of the foreign convertible bonds purchase fund is recognized as the plaintiff, the shares disposal profit after the conversion of shares shall be deemed to be reverted to the plaintiff.

(1) It is difficult to readily conclude that the subject of the transaction of overseas convertible bonds or the holder of the interest in disposal of stocks belongs to the Plaintiff, and since the ownership of the purchase fund of overseas convertible bonds is recognized by the Plaintiff through the complaint in the litigation procedure, it is reasonable to deem that the benefit in disposal of stocks after conversion of stocks is ultimately reverted to the Plaintiff.

2011Nu25786 Revocation of Disposition of Imposing global income tax, etc.

KimA

Head of the Island Tax Office

Seoul Administrative Court Decision 2010Guhap4429 decided June 30, 2011

July 25, 2012

September 5, 2012

1. The plaintiff's appeal is dismissed.

2. The costs of appeal shall be borne by the Plaintiff.

The judgment of the first instance shall be revoked. The imposition disposition of KRW 000 on the Plaintiff on May 1, 2009 by the Defendant shall be revoked.

1. cite the judgment of the first instance;

The reasons for the judgment of this court are as follows: the corresponding part of the judgment of the court of first instance is that the last 6th 8th st son of the judgment is "10 evidence". Article 8(2) of the Administrative Litigation Act and the main sentence of Article 420 of the Civil Procedure Act are cited. The plaintiff asserts that the share disposal profits of this case cannot be deemed to have accrued to the plaintiff even in this court. However, the plaintiff asserts that the share disposal profits of this case can not be deemed to have accrued to the plaintiff. However, the above shares disposal profits of this case can not be deemed to have accrued to the plaintiff. The plaintiff's representative director, and the qqqqqqq, and Kim Jae-r, who is the plaintiff, stated at an investigative agency that the plaintiff was actually in charge of the accounts, etc. (Articles 8-1 and 2 of this case, and the previous proceedings for the disposition of this case are completed, the evidence submitted by the plaintiff, including the plaintiff's evidence 6-1 and 7-18.

2. Conclusion

The judgment of the first instance is justifiable. The appeal filed by the plaintiff shall be dismissed.