logobeta
본 영문본은 리걸엔진의 AI 번역 엔진으로 번역되었습니다. 수정이 필요한 부분이 있는 경우 피드백 부탁드립니다.
텍스트 조절
arrow
arrow
(영문) 서울행정법원 2016.11.11 2014구합74558
종합소득세등부과처분취소
Text

1. The sum of the global income tax on the Defendant’s global income stated in the separate sheet No. 1 attached hereto, as well as the separate sheet No. 27,282,20,840, as well as

Reasons

1. Details of the disposition;

A. The Plaintiff, who became a member of the company B in 1974, worked in the clothing export department, and was ordered by the New York branch office of the above company in 1980. At this time, the Plaintiff transferred to the U.S., along with his spouse C (Marriage on January 20, 197), South D (E) and mag F (G).

The Republic of Korea H(I) was born in the JS and acquired U.S. citizenship, around December 1988, the plaintiff and the other family members acquired the permanent residency of the United States, and D on March 24, 2006, and F on June 7, 2013, respectively.

B. 1) The Plaintiff set aside a company B in 1990 and set aside a company on June 5, 1990, Gangnam-gu Seoul Ma building on the ground (hereinafter “instant building”).

K Co., Ltd. (hereinafter referred to as “K”) whose principal office is B.

2) After K’s purchase of raw and secondary materials necessary therefor (such as various kinds of , room, spath, spath, and other large spath, etc. necessary for manufacture) from its customers and supply them to its subsidiary, K engaged in the manufacturing and export business of clothing in such a manner that it manufactured and shipped goods to its customers as above with raw and secondary materials supplied by its subsidiary as above, and at the request of its customers. 2) The Plaintiff was registered as K’s representative director or director from May 1, 2005 until March 30, 201, but the Plaintiff was registered as K’s representative director or director from May 1, 2005 to March 30, 201. From 2006 to 2010, K received the benefits of KRW 480,000,000,000 from K as total from around 480,000 to 20,000.

C. 1) A corporation in Hong Kong (hereinafter referred to as “O”) located in Hong Kong

Around May 9, 2001, F and H own 250,000 U.S. dollars 500,000 (1 U.S. dollars per share, 500,000 U.S. dollars) as capital, and P and R (S) were listed as a director of theO. (2) From the time of establishment of theO, F and H hold 250,000 U.S. dollars.

arrow