• Korean small business review
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• v.31 no.2
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• pp.85-102
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• 2009

With the continued globalization of world markets, transfer pricing has become one of the dominant sources of controversy in international taxation. Transfer pricing is the process by which a multinational corporation calculates a price for goods and services that are transferred to affiliated entities. Consider a Korean electronic enterprise that buys supplies from its own subsidiary located in China. How much the Korean parent company pays its subsidiary will determine how much profit the Chinese unit reports in local taxes. If the parent company pays above normal market prices, it may appear to have a poor profit, even if the group as a whole shows a respectable profit margin. In this way, transfer prices impact the taxable income reported in each country in which the multinational enterprise operates. It's importance lies in that around 60% of international trade involves transactions between two related parts of multinationals, according to the OECD. Multinational enterprises (hereafter MEs) exert much effort into utilizing organizational advantages to make global investments. MEs wish to minimize their tax burden. So MEs spend a fortune on economists and accountants to justify transfer prices that suit their tax needs. On the contrary, local governments are not prepared to cope with MEs' powerful financial instruments. Tax authorities in each country wish to ensure that the tax base of any ME is divided fairly. Thus, both tax authorities and MEs have a vested interest in the way in which a transfer price is determined, and this is why MEs' international transfer prices are at the center of disputes concerned with taxation. Transfer pricing issues and practices are sometimes difficult to control for regulators because the tax administration does not have enough staffs with the knowledge and resources necessary to understand them. The authors examine transfer pricing practices to provide relevant resources useful in designing tax incentives and regulation schemes for policy makers. This study focuses on identifying the relevant business and environmental factors that could influence the international transfer pricing of MEs. In this perspective, we empirically investigate how the management perception of related variables influences their choice of international transfer pricing methods. We believe that this research is particularly useful in the design of tax policy. Because it can concentrate on a few selected factors in consideration of the limited budget of the tax administration with assistance of this research. Data is composed of questionnaire responses from foreign firms in Korea with investment balances exceeding one million dollars in the end of 2004. We mailed questionnaires to 861 managers in charge of the accounting departments of each company, resulting in 121 valid responses. Seventy six percent of the sample firms are classified as small and medium sized enterprises with assets below 100 billion Korean won. Reviewing transfer pricing methods, cost-based transfer pricing is most popular showing that 60 firms have adopted it. The market-based method is used by 31 firms, and 13 firms have reported the resale-pricing method. Regarding the nationalities of foreign investors, the Japanese and the Americans constitute most of the sample. Logistic regressions have been performed for statistical analysis. The dependent variable is binary in that whether the method of international transfer pricing is a market-based method or a cost-based method. This type of binary classification is founded on the belief that the market-based method is evaluated as the relatively objective way of pricing compared with the cost-based methods. Cost-based pricing is assumed to give mangers flexibility in transfer pricing decisions. Therefore, local regulatory agencies are thought to prefer market-based pricing over cost-based pricing. Independent variables are composed of eight factors such as corporate tax rate, tariffs, relations with local tax authorities, tax audit, equity ratios of local investors, volume of internal trade, sales volume, and product life cycle. The first four variables are included in the model because taxation lies in the center of transfer pricing disputes. So identifying the impact of these variables in Korean business environments is much needed. Equity ratio is included to represent the interest of local partners. Volume of internal trade was sometimes employed in previous research to check the pricing behavior of managers, so we have followed these footsteps in this paper. Product life cycle is used as a surrogate of competition in local markets. Control variables are firm size and nationality of foreign investors. Firm size is controlled using dummy variables in that whether or not the specific firm is small and medium sized. This is because some researchers report that big firms show different behaviors compared with small and medium sized firms in transfer pricing. The other control variable is also expressed in dummy variable showing if the entrepreneur is the American or not. That's because some prior studies conclude that the American management style is different in that they limit branch manger's freedom of decision. Reviewing the statistical results, we have found that managers prefer the cost-based method over the market-based method as the importance of corporate taxes and tariffs increase. This result means that managers need flexibility to lessen the tax burden when they feel taxes are important. They also prefer the cost-based method as the product life cycle matures, which means that they support subsidiaries in local market competition using cost-based transfer pricing. On the contrary, as the relationship with local tax authorities becomes more important, managers prefer the market-based method. That is because market-based pricing is a better way to maintain good relations with the tax officials. Other variables like tax audit, volume of internal transactions, sales volume, and local equity ratio have shown only insignificant influence. Additionally, we have replaced two tax variables(corporate taxes and tariffs) with the data showing top marginal tax rate and mean tariff rates of each country, and have performed another regression to find if we could get different results compared with the former one. As a consequence, we have found something different on the part of mean tariffs, that shows only an insignificant influence on the dependent variable. We guess that each company in the sample pays tariffs with a specific rate applied only for one's own company, which could be located far from mean tariff rates. Therefore we have concluded we need a more detailed data that shows the tariffs of each company if we want to check the role of this variable. Considering that the present paper has heavily relied on questionnaires, an effort to build a reliable data base is needed for enhancing the research reliability.

• Journal of Bio-Environment Control
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• v.5 no.2
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• pp.215-235
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• 1996

The thermal analysis by mathematical model simulation makes it possible to reasonably predict heating and/or cooling requirements of certain greenhouses located under various geographical and climatic environment. It is another advantages of model simulation technique to be able to make it possible to select appropriate heating system, to set up energy utilization strategy, to schedule seasonal crop pattern, as well as to determine new greenhouse ranges. In this study, the control pattern for greenhouse microclimate is categorized as cooling and heating. Dynamic model was adopted to simulate heating requirements and/or energy conservation effectiveness such as energy saving by night-time thermal curtain, estimation of Heating Degree-Hours(HDH), long time prediction of greenhouse thermal behavior, etc. On the other hand, the cooling effects of ventilation, shading, and pad ||||&|||| fan system were partly analyzed by static model. By the experimental work with small size model greenhouse of 1.2m$\times$2.4m, it was found that cooling the greenhouse by spraying cold water directly on greenhouse cover surface or by recirculating cold water through heat exchangers would be effective in greenhouse summer cooling. The mathematical model developed for greenhouse model simulation is highly applicable because it can reflects various climatic factors like temperature, humidity, beam and diffuse solar radiation, wind velocity, etc. This model was closely verified by various weather data obtained through long period greenhouse experiment. Most of the materials relating with greenhouse heating or cooling components were obtained from model greenhouse simulated mathematically by using typical year(1987) data of Jinju Gyeongnam. But some of the materials relating with greenhouse cooling was obtained by performing model experiments which include analyzing cooling effect of water sprayed directly on greenhouse roof surface. The results are summarized as follows : 1. The heating requirements of model greenhouse were highly related with the minimum temperature set for given greenhouse. The setting temperature at night-time is much more influential on heating energy requirement than that at day-time. Therefore It is highly recommended that night- time setting temperature should be carefully determined and controlled. 2. The HDH data obtained by conventional method were estimated on the basis of considerably long term average weather temperature together with the standard base temperature(usually 18.3$^{\circ}C$). This kind of data can merely be used as a relative comparison criteria about heating load, but is not applicable in the calculation of greenhouse heating requirements because of the limited consideration of climatic factors and inappropriate base temperature. By comparing the HDM data with the results of simulation, it is found that the heating system design by HDH data will probably overshoot the actual heating requirement. 3. The energy saving effect of night-time thermal curtain as well as estimated heating requirement is found to be sensitively related with weather condition: Thermal curtain adopted for simulation showed high effectiveness in energy saving which amounts to more than 50% of annual heating requirement. 4. The ventilation performances doting warm seasons are mainly influenced by air exchange rate even though there are some variations depending on greenhouse structural difference, weather and cropping conditions. For air exchanges above 1 volume per minute, the reduction rate of temperature rise on both types of considered greenhouse becomes modest with the additional increase of ventilation capacity. Therefore the desirable ventilation capacity is assumed to be 1 air change per minute, which is the recommended ventilation rate in common greenhouse. 5. In glass covered greenhouse with full production, under clear weather of 50% RH, and continuous 1 air change per minute, the temperature drop in 50% shaded greenhouse and pad ＆ fan systemed greenhouse is 2.6$^{\circ}C$ and.6.1$^{\circ}C$ respectively. The temperature in control greenhouse under continuous air change at this time was 36.6$^{\circ}C$ which was 5.3$^{\circ}C$ above ambient temperature. As a result the greenhouse temperature can be maintained 3$^{\circ}C$ below ambient temperature. But when RH is 80%, it was impossible to drop greenhouse temperature below ambient temperature because possible temperature reduction by pad ||||&|||| fan system at this time is not more than 2.4$^{\circ}C$. 6. During 3 months of hot summer season if the greenhouse is assumed to be cooled only when greenhouse temperature rise above 27$^{\circ}C$, the relationship between RH of ambient air and greenhouse temperature drop($\Delta$T) was formulated as follows : $\Delta$T= -0.077RH＋7.7 7. Time dependent cooling effects performed by operation of each or combination of ventilation, 50% shading, pad ＆ fan of 80% efficiency, were continuously predicted for one typical summer day long. When the greenhouse was cooled only by 1 air change per minute, greenhouse air temperature was 5$^{\circ}C$ above outdoor temperature. Either method alone can not drop greenhouse air temperature below outdoor temperature even under the fully cropped situations. But when both systems were operated together, greenhouse air temperature can be controlled to about 2.0-2.3$^{\circ}C$ below ambient temperature. 8. When the cool water of 6.5-8.5$^{\circ}C$ was sprayed on greenhouse roof surface with the water flow rate of 1.3 liter/min per unit greenhouse floor area, greenhouse air temperature could be dropped down to 16.5-18.$0^{\circ}C$, whlch is about 1$0^{\circ}C$ below the ambient temperature of 26.5-28.$0^{\circ}C$ at that time. The most important thing in cooling greenhouse air effectively with water spray may be obtaining plenty of cool water source like ground water itself or cold water produced by heat-pump. Future work is focused on not only analyzing the feasibility of heat pump operation but also finding the relationships between greenhouse air temperature(T$_{g}$ ), spraying water temperature(T$_{w}$ ), water flow rate(Q), and ambient temperature(T$_{o}$).

• Korean Journal of Agricultural Science
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• v.4 no.2
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• pp.254-282
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• 1977

To obtain information on the inheritance of the quantitative characters related with the vegetative and reproductive growth of rice, the $F_1$ seeds were obtained in 1974 from the all possible combinations of the diallel crosses among five leading rice varieties : Nongbaek, Tongil, Palgueng, Mangyeong and Gimmaze. The $F_1$'s including reciprocals and parents were grown under the standard cultivation method at Chungnam Provincial Office of Rural Development in 1975. The arrangement of experimental plots was randomized block design with 3 replications and 12 characters were used for the analysis. Analytical procedure for genetic components was followed the Griffing's and Hayman's methods and the results obtained are summarized as follows. 1. In all $F_1$'s of Tongil crosses, the longer duration to heading was due to dominant effect of Tongil and each $F_1$ showed high heterosis in delaying the heading time. It was assumed that non-allelic gene action besides dominant gene effect might be involed in days to heading character. However, in all $F_1$'s from the crosses among parents excluding Tongil the shorter duration was due to dominant gene action and the degree of dominance was partial, since dominance effects were not greater than the additive effect. The non-allelic gene interaction was not significant. Considering the results mentioned above, it was regarded that there were two kinds of Significantly different genetic systems in the days to heading. 2. The rate of heterosis was significantly different depending upon the parents used in the crosses. For instance, the $F_1$'s from Togil cross showed high rate of heterosis in longer culm. Compared to short culm, longer culm was due to recesive gene action and short culm was due to recesive gene action. The dominant gene effect was greater than the additive gene effect in culm length. The narrow sense of heretability was very low and the maternal effects as well as reciprocal effects were significantly recognized. 3. The lenght of the of the uppermost internode of each $F_1$ plant was a little lorger than these of respective parental means or same as those of parents having long internodes, indicating partial dominance in the direction of lengthening the uppermost internodes. The additive gene effects on the uppermost internode was greater than the dominance gene effect. The narrow as well as broad sense of heritabilities for the character of the uppermost internode were very high. There were significant maternal and reciprocal effect in the uppermost internode. 4. The gene action for the flag leaf angle was rather dominance in a way of getting narrower angle. However, in the Palgueng combinations, heterosis of $F_1$ was observed in both narrow and wide angles of the flag leaf. The dominant effects were greater than the additive effects on the flag leaf angle. There were observed also a great deal of non-allelic gene interacticn on the inheritance of the flag leaf angle. 5. Even though the dominant gene action on the length and width of flag leaf was effective in increasing the length or width of the flag leaf, there were found various degrees of hetercsis depending upon the cross combination. Over-dominant gene effect were observed in the inheritance of length of the flag leaf, while additive gene effects was found in the inheritance of the width of the flag leaf. High degree of heretabilities, either narrow or broad sense, were found in both length and width of the flag leaf. No maternal and reciprocal effect were found in both characters. 6. When Tongil was used as one parent in the cross, the length of panicle of $F_1$'s was remarkedly longer than that of parents. In other cross comination, the length of panicle of $F_1$'s was close to the parental mean values. Rather greater dominent gene effect than additive gene effect was observed in the inheritance of panicle length and the dominant gene was effective in increasing the panicle length. 7. The effect of dominant genes was effective in increasing the number of panicles. The degree of heterosis was largely dependent on the cross combination. The effect of dominant gene in the inheritance of panicle number was a little greater than that of additive genes, and the inheritance of panicle number was assumed to be due to complete dominant gene effects. Significantly high maternal and reciprocal effects were found in the character studied. 8. There were minus and plus values of heterosis in the kernel number per panicle depending upon the cross combination. The mean dominant effect was effective in increasing the kernel number per panicle, the degree of dominant effect varied with cross combination. The dominant gene effect and non-allelic gene interaction were found in the inheritance of the kernel number per panicle. 9. Genetic studies were impossible for the maturing ratio, because of environmental effects such as hazards delaying heads. The dominant gene effect was responsible for improving the maturing ratio in all the cross combinations excluding Tongil 10. The heavier 1000 grain weight was due to dominant gene effects. The additive gene effects were greater than the dominant gene effect in the 1000 grain weight, indicating that partial dominance was responsible for increasing the 1000 grain weight. The heritabilites, either narrow or broad sense of, were high for the grain weight and maternal or reciprocal effects were not recognized. 11. When Tongil was used as parent, the straw weight was showing high heterosis in the direction of increasing the weight. But in other crosses, the straw weight of $F_1$'s was lower than those of parental mean values. The direction of dominant gene effect was plus or minus depending upon the cross combinations. The degree of dominance was also depending on the cross combination, and apparently high nonallelic gene interaction was observed.

• Korean Journal of Heritage: History & Science
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• v.44 no.4
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• pp.172-205
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• 2011

Go bears significant meanings in terms of cultural and entertaining functions in Asia Eastern such as China and Japan. Beyond the mere entertaining level, it produces philosophical and mythic discourse as well. As a part of effort to seek an identity of Korean traditional garden culture, this study traced back to find meanings of rock-go-board and taste for the arts which ancestors pursued in playing Go game, through analysis and interpretation of correlation among origin of place name, nearby scenery, carved letters and vicinal handed-down place name. At the same time, their position, shape and location types were interpreted through comprehensive research and analysis of stone-go-boards including rock-go-board. Particularly, it focused on the rock names related to Sundoism(仙道) Ideal world, fixed due to a connection between traces of Sundoism and places in a folk etymology. Series of this work is to highlight features of the immortal sceneries, one of traditional landscaping ideals, by understanding place identity and scenic features of where the rock-go-boards are carved. These works are expected to become foundation for promotion and preservation of the traditional landscaping remains. The contents of this study could be summarized as follows; First, round stone and square board for round sky and angled land, black and white color for harmony of yin and yang and 361paths for rotating sky are symbols projecting order of universe. Sayings of Gyuljungjirak(橘中之樂), Sangsansaho(商山四皓), Nangagosa(爛柯故事) formed based on the idea of eternity stand for union of sky and sun. It indicates Go game which matches life and nature spatiotemporally and elegant taste for arts pursuing beauty and leisure. Second, the stone-go-boards found through this research, are 18 in total. 3 of those(16.1%), Gangjin Weolnamsaji, Yangsan Sohanjeong and Banryongdae ones were classified into movable Seokguk and 15(83.9%) including Banghakdong were turned out to be non-movable rock-go-boards carved on natural rocks. Third, upon the result of materializing location types of rock-go-boards, 15 are mountain stream type(83.9%) and 3 are rock peak type(16.1%). Among those, the one at Sobaeksam Sinseonbong is located at the highest place(1,389m). Considering the fact that all of 15 rock-go-boards were found at mountainous areas lower than 500m, it is recognizable that where the Go-boards are the parts of the living space, not far from secular world. Fourth, there are 7 Sunjang(巡將) Go with 17 Hwajeoms(花點), which is a traditional Go board type, but their existences, numbers and shapes of Hwajeom appear variously. Based on the fact, it is recognizable that culture of making go-board had been handed down for an extended period of time. Among the studied rock-goboards, the biggest one was Muju Sasunam[$80(82)cm{\times}80(82)cm$] while the smallest one was Yangsan Sohandjeong Seokguk ($40cm{\times}40cm$). The dimension of length and breadth are both $49cm{\times}48cm$ on average, which is realistic size for actual Go play. Fifth, the biggest bed rock, an under-masonry with carved Go-board on it, was one in Muju Sasunam[$8.7m{\times}7.5m(65.25m^2)$], followed by ones in Hoengseong Chuiseok[$7.8m{\times}6.3m(49.14m^2$] and Goisan Sungukam[$6.7m{\times}5.7m(37.14m^2)$]. Meanwhile, the smallest rock-go-board was turned out to be one in Seoul Banghak-dong. There was no consistency in directions of the Go-boards, which gives a hint that geographical features and sceneries of locations were considered first and then these were carved toward an optimal direction corresponding to the conditions. Sixth, rock-go-boards were all located in valleys and peaks of mountains with breathtaking scenery. It seems closely related to ancestors' taste for arts. Particularly, rock-go-boards are apprehended as facilities related to taste for arts for having leisure in many mountains and big streams under the idea of union of sky and human as a primitive communal line. Go became a medium of hermits, which is a traditional image of Go-game, and symbol of amusement and entertainment with the idea that Go is an essence of scholar culture enabling to reach the Tao of turning back to nature. Seventh, the further ancient time going back to, the more dreamlike the Go-boards are. It is an evident for that Sundoism, which used to be unacceptable once, became more visible and realistic. Considering the high relation between rock-go-boards and Sundoism relevant names such as Sundoism peak in Danyang Sobaeksan, 4 hermits rock in Muju and Sundoism hermit rock in Jangsu, Sundoism hermit rocks and rock-go-boards are sceneries and observation spots to express a communication of worship and longing for Sundoism. Eighth, 3 elements-physical environment such as location type of the rock-go-boards, human activities concentrated on 8 sceneries and Dongcheongugok(洞天九曲) setup and relevancy to Confucian scholars, as well as 'Sangsansaho' motif and 'Nangagosa' symbolic meaning were used as interpretation tools in order to judge the place identity. Upon the result, spatial investigation is required with respect to Sunyoodongcheon(仙遊洞天) concept based on enjoyment to unify with the nature rather than Dongcheongugok concept of neo-Confucian, for Dongcheon and Dongmoon(洞門) motives carved around the rock-go-boards. Generally, places where mountain stream type rock-go-boards were formed were hermit spaces of Confucianism or Sundoism. They are considered to have compromised one other with the change of times. Particularly, in the rock-go-board at the mountain peak, sublimity-oriented advent of Sundoism is considered as a significant factor to control place identity. Ninth, including where the rock-go-boards were established, the vicinal areas are well-known as parts of Dongcheongugok and Palkyung(八景) mostly. In addition, many of Sundoism relevant expressions were discovered even in the neighboring carvings written by scholars and nobility, which means sophisticated taste based on longing for Sundoism world played a significant role in making go-board. The rock-go-board is an integration of cultural phenomena naturally managed by seclusion of scholars in the Joseon Dynasty as well as remains and essence of Korean traditional landscaping. Some rock-go-boards out of 17 discovered in South Korea, including ones in Sobaeksan Sinsunbong, Banghak-dong, Chungju Gongili, Muju Sasunam, Yangsan Eogokdong Banryongdae Seokguk, are damaged such as cracks in rocks or fainted lines by hardships of time and hand stains. Worse yet, in case of Eunyang Bangudae Jipcheongjeong board, it is very difficult to identify the shape due to being buried. Rock-go-boards are valuable sculptures in terms of cultural asset and artwork since they reflect ancestors' love for nature and longing for Sundoism world. Therefore, they should be maintained properly with right preservation method. Not only rock-boards itself but also peripheral places are excellent cultural heritages and crucial cultural assets. In addition, vicinal sceneries of where rock-goboards and pavilion spots are the representative remains of embracing prototype of Korean traditional landscaping and major parts of cultural properties.