Enforcement Rules of the Estate and Gift Tax Act Article 28-1

The valuation of the securities that has been privately placed in the Securities and Exchange Act, if securities of the same type as those to be offered and issued on the exchange listed, OTC listed securities, or emerging company securities on the date of inheritance of gift shall be valued by the following rules：1. The lower one of the closing price of the exchange listed securities or the OTC listed securities on the date of inheritance or gift and the average of all the closing prices of such securities traded one month preceding the date of inheritance or gift. Where no dealing price of said securities was available on such date, the valuation of such securities shall be based upon the lower one of the closing price of the exchange listed, OTC listed securities traded on the last date immediately preceding the date of inheritance or gift and the average of all the closing prices of such securities, traded one month preceding the last date immediately preceding the date of inheritance or gift. If there is no such average of all closing prices within one month preceding the date, the valuation of such securities shall be based upon the closing price of such securities on the date of inheritance or gift. Where no dealing price of said securities was available on such date, the closing price of such securities traded on the last date immediately preceding the date of inheritance or gift shall be used in determination of the value.2. The valuation of emerging company privately placed securities shall be based upon the lower one of the weighted average dealing price of the emerging company securities traded on the date of inheritance or gift and the average of all the weighted average dealing price of such securities traded one month preceding the date of inheritance or gift. Where no dealing price of said securities was available on such date, the valuation of such securities shall be based upon the lower one of the weighted average dealing price of the emerging company securities traded on the last date immediately preceding the date of inheritance or gift and the average of all the weighted average dealing price of such securities, traded one month preceding the last date immediately preceding the date of inheritance or gift. If there is no such average of all weighted average dealing prices within one month preceding the date, the valuation of such securities shall be based upon the weighted average dealing price the emerging company securities traded on the date of inheritance or gift. Where no dealing price of said securities was available on such date, the weighted average dealing price of emerging company securities traded on the last date immediately preceding the date of inheritance or gift shall be used in determination of the value.Valuation of privately placed securities of companies limited by common shares other than exchange listed, OTC listed, or emerging company shall be based upon the net worth of the company’s assets on the date of inheritance or gift, the value shall be adjustmented according to the first and second Paragraph of Article 29.