한국의 가상자산 상속세 및 증여세 평가체계 개선방안：조세회피 방지와 부의 이전 규율을 중심으로 = Improving Korea’s Virtual Asset Inheritance and Gift Tax Valuation System ：Preventing Tax Avoidance and Wealth Transfer Abuse

다국어 초록 (Multilingual Abstract)

This study examines the limitations of Korea’s inheritance and gift tax framework in dealing with virtual assets and proposes Korea－specific reforms focusing on the prevention of tax avoidance and the regulation of intergenerational wealth transfers. First, by analyzing the current Inheritance and Gift Tax Act, relevant enforcement decrees, and administrative interpretations, the study identifies major institutional weaknesses, including the absence of clear valuation rules, price discrepancies across exchanges, the lack of guidance for delisted or illiquid tokens, and the high potential for asset concealment through private and foreign wallets. Second, it analyzes how structural features of virtual assets－such as extreme price volatility, time and exchange arbitrage, internal ICOs, and cross－border transferability－undermine the ability－to－pay principle and tax equity, thereby distorting wealth transfer patterns and eroding the tax base. Third, by comparing the regulatory approaches of the United States, the United Kingdom, Germany, Japan, and non－inheritance－tax jurisdictions such as Singapore, the study derives key implications regarding fair market value and market value standards, practical valuation guidelines, and wallet reporting and tracking mechanisms. Based on these findings, the paper proposes a set of reforms for Korea, including codified valuation rules using VWAP and reference price systems, mandatory reporting of wallet addresses and private keys in inheritance and gift cases, strengthened rules on foreign transfers and offshore taxation, and supplementary valuation regimes for NFTs and LP tokens. The study contributes to the literature and policy debate by providing an integrated legal, economic, and technical analysis of virtual assets within the inheritance and gift tax system, thereby offering a foundation for fair and effective digital asset taxation