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| TITLE | Supreme Court Decision 2019Do11381 Decided March 12, 2020 ¡¼Violation of the Adjustment of International Taxes Act¡½ [full Text] |
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| Summary | |
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Whether standards for determining a domestic corporation (referred to as a wholly owning parent company), which owns, directly or indirectly, 100/100 of the voting stocks of a foreign corporation (referred to as a wholly owned subsidiary), as an actual holder may be included in ¡°standards for determining persons required to report,¡± which will be specified in the enforcement decree in accordance with the delegation of Article 34(6) of the former Adjustment of International Taxes Act (affirmative) Whether the parenthesis part in Article 50(4) main text of the former Enforcement Decree of the Adjustment of International Taxes Act, stipulating a domestic corporation, a wholly owning parent company, as an actual holder of an overseas financial account, whose nominal holder is a foreign corporation, a wholly owned subsidiary, is considered null and void by exceeding the bounds of delegation prescribed in Article 34(6) of the former Adjustment of International Taxes Act (negative) |
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