LG's ₩2.3 trillion: on Thursday a court refused to undo the adoption. On Friday the inheritance appeal opened

Start with the thing Singapore actually removes, because it is large and it is often overstated. Korea has forced heirship. Article 1112 of the Civil Act gives descendants and the spouse half of their statutory share and ascendants a third, and it is not waivable by will; article 1114 pulls back gifts made in the year before death, and gifts made at any time where both sides knew the gift would injure a reserved-share holder. Singapore has no forced heirship for non-Muslims. A Singapore will that leaves a holding company to one child cannot be clawed back by the others; the Inheritance (Family Provision) Act 1966 permits only a narrow maintenance claim by a defined class of dependants, which is a different thing entirely. That is the structural gap, and it is why a Korean founder looks at Singapore at all. Worth noting for anyone reading the Korean law as settled: article 1115 was amended with effect from 17 March 2026 so that a reserved-share claim is now a claim for the value, with interest from the date of demand, rather than a claim to have the property itself returned. A reserved-share fight in Korea is now a money fight, not a share fight — which matters enormously to whether a control block survives one.

Then the instrument problem, which is the real lesson and travels everywhere. An adoption is a durable way to designate an heir and a terrible way to transfer an asset, because it transfers nothing. In 2004 the family decided who would run LG; in 2018 the estate still had to catch up to that decision, and catching up required a document signed by three grieving people whose statutory entitlement it reversed. A trust deed or a share transfer does the opposite: it moves the asset now and settles the status question by making it irrelevant. Nobody can petition a family court to un-sign a deed of settlement executed eight years earlier and acted on ever since. In Singapore the architecture is ordinary rather than exotic — the operating stake held through a private trust company owned by a purpose trust, a trust term of up to 100 years under Civil Law Act 1909 s32 as applied by Trustees Act 1967 s89, no public trust register, and the founder retaining the powers he genuinely needs while he is alive. The point is not secrecy. The point is that the transfer happens on a day the founder chooses, with his own signature on it, rather than on a day chosen by his death.

Now the timetable, which is where the cost actually falls. Korea taxes the estate at up to 50 per cent above a taxable base of ₩3 billion under section 26 of the Inheritance and Gift Tax Act, and section 63(3) adds 20 per cent to the valuation of a largest shareholder's shares — so the controlling block is the most expensive asset in the estate precisely because it is controlling. Section 71 lets the bill be paid in instalments against security, which is how ₩921.5 billion became six payments and a pledge over the shares. Singapore charges no estate duty at all on deaths on or after 15 February 2008, and has no inheritance, gift or net-wealth tax; a Singapore-resident holding structure funded in the founder's lifetime is simply not in that queue. Be precise about what this does and does not mean for a Korean family, though: Singapore's zero rate is not a shelter from Korea's rate. Korea taxes a Korean decedent's estate, and the assets that matter here are shares in a Korean listed company. The honest saving is not the tax. It is that the transfer, the valuation and the family conversation all happen while the founder is in the room to settle them.

So the limits, stated plainly, because a counterfactual that promises too much is how families buy litigation. Section 90 of the Trustees Act 1967 shields a Singapore-law trust with Singapore-resident trustees from foreign forced-heirship claims, but it binds a Singapore court, not a Seoul one, and it applies only where the settlor was neither a Singapore citizen nor Singapore-domiciled when the trust was created. LG Corp shares are Korean-situs property held through a Korean register; a Korean court applying Korean succession law reaches them whatever a Singapore deed says, and a Korean settlor who transfers a controlling block late in life with the reserved share in mind is squarely inside article 1114. What a Singapore structure genuinely buys a family in this position is narrower and more useful than the brochures suggest: a place to hold the international assets under one law with no forced share and no estate duty, a trustee who can pay a Korean tax instalment on the day it falls due without anyone's consent, and — most of all — a reason to have the whole conversation ten years early, in writing, while everyone is alive. Kim Young-sik and her daughters are not litigating about arithmetic. They are litigating about a conversation nobody had in 2004 and nobody could have in 2018.