Does Tax Really Matter in Planning the Dongbu Group's Spin-Offs? (세무계획측면에서 분석한 동부그룹 물적분할)
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- The Journal of Small Business Innovation
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- v.20 no.1
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- pp.1-18
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- 2017
This study examined whether divided and spun-off companies design and execute spin-offs to minimize tax burdens by analyzing multiple spin-off transactions in the Dongbu Group, when the Korean tax law regarding corporate restructuring was amended in July 2010. Before the July 2010 tax amendment, taxes on the capital gains arising from the qualifying spin-off were deferred to the earlier of the shares in or assets acquired by the spun-off company are disposed. This tax treatment relieves the divided company's tax burden by deferring taxes on capital gains, compared with non-qualifying spin-offs. However, if shares in or assets acquired by the spun-off company are disposed after the July 2010 tax amendment, the capital gain incurred at the time of the qualifying spin-off would be taxed again at the spun-off company, in addition to a taxation on the divided company's capital gains. This creates double taxation implications for the parties involved in the spin-off. As a result, the double taxation may outweigh the benefit from the tax deferral on the qualifying spin-off, which may make a qualifying spin-off tax unfavorable. Among the four spin-off cases in the Dongbu Group addressed in this study, a spin-off occurred before the tax amendment, whereas three spin-offs occurred after the tax amendment. Initially, we expected that the spin-off before the tax amendment would be a qualifying spin-off, and the other three spin-offs would be non-qualifying spin-offs, considering the taxation rules before and after the July 2010 tax amendment. However, based on the review of summarized balance sheets disclosed in the spin-offs' corporate filings, no capital gains arose during the four spin-offs that occurred in the Dongbu Group. Therefore, we concluded that the Dongbu Group considered non-tax factors more than tax factors while designing and executing the spin-offs. The local media posited during this period that these spin-offs may intend to resolve financial issues in the Dongbu Group, and this analysis was supported by the fact that some shares in the new spun-off companies were sold by the Dongbu Group. Our case studies provide evidence that all costs, including both tax and non-tax costs, must be considered in the course of spin-offs, in addition to the tax burdens on all parties involved in the corporate restructuring, which parallels the work of Scholes et al. (2008). This study provides implications that various aspects should be considered and reviewed in advance when the management makes decisions for effective tax planning.
Prunus sargentii R. of Rosaceae familiy, has been reported to have radical scavenging activity and anti-inflammatory effect. On these facts, biological activity and safety test were conducted to evaluate biological activities of the extracts of P. sargentii R. as a potential pharmaceutical ingredient. The electron donating ability of its ethanol extracts at a 500 ppm level showed 92%, which was higher than that of hot water extract (59%), the superoxide dismutase (SOD)-like activity of the water extract of P. sargentii R. was about 50%, the ethanol extract of P. sargentii R. was about 40% at 1,000 ppm concentration. Xanthine oxidase inhibition by the water extract of P. sargentii R. was about 40% and that by the ethanol extract was 60% respectively at 500 ppm concentration. From the measurement on lipid oxidation, the
Recently, the bio-healthcare market is enlarging worldwide due to various reasons such as the COVID-19 pandemic. Among them, biometric measurement and analysis technology are expected to bring about future technological innovation and socio-economic ripple effect. Existing systems require a large-capacity battery to drive signal processing, wireless transmission part, and an operating system in the process. However, due to the limitation of the battery capacity, it causes a spatio-temporal limitation on the use of the device. This limitation can act as a cause for the disconnection of data required for the user's health care monitoring, so it is one of the major obstacles of the health care device. In this study, we report the concept of a standalone healthcare monitoring module, which is based on both triboelectric effects and electromagnetic effects, by converting biomechanical energy into suitable electric energy. The proposed system can be operated independently without an external power source. In particular, the wireless foot pressure measurement monitoring system, which is rationally designed triboelectric sensor (TES), can recognize the user's walking habits through foot pressure measurement. By applying the triboelectric effects to the contact-separation behavior that occurs during walking, an effective foot pressure sensor was made, the performance of the sensor was verified through an electrical output signal according to the pressure, and its dynamic behavior is measured through a signal processing circuit using a capacitor. In addition, the biomechanical energy dissipated during walking is harvested as electrical energy by using the electromagnetic induction effect to be used as a power source for wireless transmission and signal processing. Therefore, the proposed system has a great potential to reduce the inconvenience of charging caused by limited battery capacity and to overcome the problem of data disconnection.
In venture creation research, studying 'entrepreneurial leadership' is important for uncovering and comprehending the underlying causal process in innovative behavior performance. Although previous studies provide that entrepreneurial leadership enhances followers' innovative behavior, there is few research on entrepreneurial leadership and followers' characteristics interaction. The present study's focus is paradoxical effects of entrepreneurial leadership on self-efficacy and innovative behavior. On the basis of individual regulatory focus, this study suggests that interaction effects of entrepreneurial leadership and followers' regulatory focus differed in promotion view and prevention view followers' innovative behavior. To strengthen the casual mechanism, this study conducted in priming experiment method using employees in SMEs. This study used a 2(entrepreneurial leadership vs. control) x 2 (regulatory focus: promotion vs. prevention) between-participants design. The results of this study provide that (1) Individuals in promotion focus especially benefited from entrepreneurial leadership in terms of its effect on their self-efficacy and innovative behavior; (2) whereas entrepreneurial leadership was negatively related to self-efficacy and innovative behavior of followers' prevention focus. In sum, results of the present study supporting evidence for hypotheses, combined effect of entrepreneurial leadership and regulatory focus on innovative behavior through self-efficacy. Experimental results confirmed hypotheses of this study, revealing that promotion focus show more innovative behavior than prevention focus when their leaders' leadership style is entrepreneurial leadership. Also, the paradoxical effect of entrepreneurial leadership and regulatory focus of followers on innovative behavior was mediated by followers' self-efficacy. This study helps explain how leaders' entrepreneurial leadership boost followers' innovative behavior, particularly for those employees who have promotion focus. The current study contributes to the theory of entrepreneurial leadership and regulatory focus and innovation literature. Findings of this study shed light on the organizational processes that shape innovative behavior in venture/startup corporations and provide contributions for venture business field.
Today, photography is facing to the crisis of identity and dilemma of ontology from the digital imaging process in the new technology form. It is very important points to say rethinking of the traditional photographic medium, that has changed the way we view the world and ourselves is perhaps an understatement and that photography has transformed our essential understanding of reality. Now, no longer are photographic images regarded as the true automatic recording, innocent evidence and the mirror to the reality. Rather, photography constructs the world for our entertainment, helping to create the comforting illusions by which we live. The recognition that photographs are not constructions and reflections of reality, is the basis for the actual presence within the contemporary photographic world. It is shock. This thesis's aim is to look for the problems of photographic identity and ontological crisis that is controlling and regulating digital photographic imagery, allowing the reproduction of the electronic simulations era. Photography loses its special aesthetic status and becomes no more true information and, exclusively evidence by traditional film and paper that appeared both as a technological accuracy and as a medium-specific aesthetic. The result, photography is facing two crises, one is the photographic ontology(the introduction of computerized digital images) and the other is photographic epistemology(having to do broader changes in ethics, knowledge and culture). Taken together, these crises apparently threaten us with the death of photography, with the 'end' of photography and the culture it sustains. The thesis's meaning is to look into the dilemma of photography's ontology and epistemology, especially, automatical index and digital codes from its origin, meaning, and identity as the technological medium. Thus, in particular, thesis focuses on the analog imagery presence, from the nature in the material world, and the digital imagery presence from the cultural situations in our society. And also thesis's aim is to examine the main issues of the history of photography has been concentrated on the ontological arguments since the discovery of photography in 1839. Photography has never been only one static technology form. Rather, its nearly two centuries of technological development have been marked by numerous, competing of technological innovation and self revolution from the dual aspects. This thesis examines recent account of photography by the analysis of the medium's concept, meaning, identity between film base image and digital base image from the aspects of photographic ontology and epistemology. Thus, the structure of thesis is fairy straightforward to examine what appear to be two opposing view of photographic conditions and ontological situations. Thesis' view contrasts that figure out the value of photography according to its fundamental characteristic as a medium. Also, it seeks a possible solution to the dilemma of photographic ontology through the medium's origin from the early years of the nineteenth century to the raising questions about the different meaning(analog/digital) of photography, now. Finally, this thesis emphasizes and concludes that the photographic ontological crisis reflects to the paradoxical dynamic structure, that unsolved the origins of the medium, itself. Moreover, even photography is not single identity of the photographic ontology, and also can not be understood as having a static identity or singular status from the dynamic field of technologies, practices, and images.
With rapid development of ICT (Information and Communications Technology), new services by the convergence of mobile network and application technology began to appear. Today, smart phone with new ICT convergence network capabilities is exceedingly popular and very useful as a new tool for the development of business opportunities. Previous studies based on Technology Acceptance Model (TAM) suggested critical factors, which should be considered for acquiring new customers and maintaining existing users in smart phone market. However, they had a limitation to focus on technology acceptance, not value based approach. Prior studies on customer's adoption of electronic utilities like smart phone product showed that the antecedents such as the perceived benefit and the perceived sacrifice could explain the causality between what is perceived and what is acquired over diverse contexts. So, this research conceptualizes perceived value as a trade-off between perceived benefit and perceived sacrifice, and we need to research the perceived value to grasp user's continuous intention to use of smart phone. The purpose of this study is to investigate the structured relationship between benefit (quality, usefulness, playfulness) and sacrifice (technicality, cost, security risk) of smart phone users, perceived value, and continuous intention to use. In addition, this study intends to analyze the differences between two subgroups of smart phone users by the degree of personal innovativeness. Personal innovativeness could help us to understand the moderating effect between how perceptions are formed and continuous intention to use smart phone. This study conducted survey through e-mail, direct mail, and interview with smart phone users. Empirical analysis based on 330 respondents was conducted in order to test the hypotheses. First, the result of hypotheses testing showed that perceived usefulness among three factors of perceived benefit has the highest positive impact on perceived value, and then followed by perceived playfulness and perceived quality. Second, the result of hypotheses testing showed that perceived cost among three factors of perceived sacrifice has significantly negative impact on perceived value, however, technicality and security risk have no significant impact on perceived value. Also, the result of hypotheses testing showed that perceived value has significant direct impact on continuous intention to use of smart phone. In this regard, marketing managers of smart phone company should pay more attention to improve task efficiency and performance of smart phone, including rate systems of smart phone. Additionally, to test the moderating effect of personal innovativeness, this research conducted multi-group analysis by the degree of personal innovativeness of smart phone users. In a group with high level of innovativeness, perceived usefulness has the highest positive influence on perceived value than other factors. Instead, the analysis for a group with low level of innovativeness showed that perceived playfulness was the highest positive factor to influence perceived value than others. This result of the group with high level of innovativeness explains that innovators and early adopters are able to cope with higher level of cost and risk, and they expect to develop more positive intentions toward higher performance through the use of an innovation. Also, hedonic behavior in the case of the group with low level of innovativeness aims to provide self-fulfilling value to the users, in contrast to utilitarian perspective, which aims to provide instrumental value to the users. However, with regard to perceived sacrifice, both groups in general showed negative impact on perceived value. Also, the group with high level of innovativeness had less overall negative impact on perceived value compared to the group with low level of innovativeness across all factors. In both group with high level of innovativeness and with low level of innovativeness, perceived cost has the highest negative influence on perceived value than other factors. Instead, the analysis for a group with high level of innovativeness showed that perceived technicality was the positive factor to influence perceived value than others. However, the analysis for a group with low level of innovativeness showed that perceived security risk was the second high negative factor to influence perceived value than others. Unlike previous studies, this study focuses on influencing factors on continuous intention to use of smart phone, rather than considering initial purchase and adoption of smart phone. First, perceived value, which was used to identify user's adoption behavior, has a mediating effect among perceived benefit, perceived sacrifice, and continuous intention to use smart phone. Second, perceived usefulness has the highest positive influence on perceived value, while perceived cost has significant negative influence on perceived value. Third, perceived value, like prior studies, has high level of positive influence on continuous intention to use smart phone. Fourth, in multi-group analysis by the degree of personal innovativeness of smart phone users, perceived usefulness, in a group with high level of innovativeness, has the highest positive influence on perceived value than other factors. Instead, perceived playfulness, in a group with low level of innovativeness, has the highest positive factor to influence perceived value than others. This result shows that early adopters intend to adopt smart phone as a tool to make their job useful, instead market followers intend to adopt smart phone as a tool to make their time enjoyable. In terms of marketing strategy for smart phone company, marketing managers should pay more attention to identify their customers' lifetime value by the phase of smart phone adoption, as well as to understand their behavior intention to accept the risk and uncertainty positively. The academic contribution of this study primarily is to employ the VAM (Value-based Adoption Model) as a conceptual foundation, compared to TAM (Technology Acceptance Model) used widely by previous studies. VAM is useful for understanding continuous intention to use smart phone in comparison with TAM as a new IT utility by individual adoption. Perceived value dominantly influences continuous intention to use smart phone. The results of this study justify our research model adoption on each antecedent of perceived value as a benefit and a sacrifice component. While TAM could be widely used in user acceptance of new technology, it has a limitation to explain the new IT adoption like smart phone, because of customer behavior intention to choose the value of the object. In terms of theoretical approach, this study provides theoretical contribution to the development, design, and marketing of smart phone. The practical contribution of this study is to suggest useful decision alternatives concerned to marketing strategy formulation for acquiring and retaining long-term customers related to smart phone business. Since potential customers are interested in both benefit and sacrifice when evaluating the value of smart phone, marketing managers in smart phone company has to put more effort into creating customer's value of low sacrifice and high benefit so that customers will continuously have higher adoption on smart phone. Especially, this study shows that innovators and early adopters with high level of innovativeness have higher adoption than market followers with low level of innovativeness, in terms of perceived usefulness and perceived cost. To formulate marketing strategy for smart phone diffusion, marketing managers have to pay more attention to identify not only their customers' benefit and sacrifice components but also their customers' lifetime value to adopt smart phone.
1. Introduction Today Internet is recognized as an important way for the transaction of products and services. According to the data surveyed by the National Statistical Office, the on-line transaction in 2007 for a year, 15.7656 trillion, shows a 17.1%(2.3060 trillion won) increase over last year, of these, the amount of B2C has been increased 12.0%(10.2258 trillion won). Like this, because the entry barrier of on-line market of Korea is low, many retailers could easily enter into the market. So the bigger its scale is, but on the other hand, the tougher its competition is. Particularly due to the Internet and innovation of IT, the existing market has been changed into the perfect competitive market(Srinivasan, Rolph & Kishore, 2002). In the early years of on-line business, they think that the main reason for success is a moderate price, they are awakened to its importance of on-line service quality with tough competition. If it's not sure whether customers can be provided with what they want, they can use the Web sites, perhaps they can trust their products that had been already bought or not, they have a doubt its viability(Parasuraman, Zeithaml & Malhotra, 2005). Customers can directly reserve and issue their air tickets irrespective of place and time at the Web sites of travel agencies or airlines, but its empirical studies about these Web sites for reserving and issuing air tickets are insufficient. Therefore this study goes on for following specific objects. First object is to measure service quality and service recovery of Web sites for reserving and issuing air tickets. Second is to look into whether above on-line service quality and on-line service recovery have an impact on overall service quality. Third is to seek for the relation with overall service quality and customer satisfaction, then this customer satisfaction and loyalty intention. 2. Theoretical Background 2.1 On-line Service Quality Barnes & Vidgen(2000; 2001a; 2001b; 2002) had invented the tool to measure Web sites' quality four times(called WebQual). The WebQual 1.0, Step one invented a measuring item for information quality based on QFD, and this had been verified by students of UK business school. The Web Qual 2.0, Step two invented for interaction quality, and had been judged by customers of on-line bookshop. The WebQual 3.0, Step three invented by consolidating the WebQual 1.0 for information quality and the WebQual2.0 for interactionquality. It includes 3-quality-dimension, information quality, interaction quality, site design, and had been assessed and confirmed by auction sites(e-bay, Amazon, QXL). Furtheron, through the former empirical studies, the authors changed sites quality into usability by judging that usability is a concept how customers interact with or perceive Web sites and It is used widely for accessing Web sites. By this process, WebQual 4.0 was invented, and is consist of 3-quality-dimension; information quality, interaction quality, usability, 22 items. However, because WebQual 4.0 is focusing on technical part, it's usable at the Website's design part, on the other hand, it's not usable at the Web site's pleasant experience part. Parasuraman, Zeithaml & Malhorta(2002; 2005) had invented the measure for measuring on-line service quality in 2002 and 2005. The study in 2002 divided on-line service quality into 5 dimensions. But these were not well-organized, so there needed to be studied again totally. So Parasuraman, Zeithaml & Malhorta(2005) re-worked out the study about on-line service quality measure base on 2002's study and invented E-S-QUAL. After they invented preliminary measure for on-line service quality, they made up a question for customers who had purchased at amazon.com and walmart.com and reassessed this measure. And they perfected an invention of E-S-QUAL consists of 4 dimensions, 22 items of efficiency, system availability, fulfillment, privacy. Efficiency measures assess to sites and usability and others, system availability measures accurate technical function of sites and others, fulfillment measures promptness of delivering products and sufficient goods and others and privacy measures the degree of protection of data about their customers and so on. 2.2 Service Recovery Service industries tend to minimize the losses by coping with service failure promptly. This responses of service providers to service failure mean service recovery(Kelly & Davis, 1994). Bitner(1990) went on his study from customers' view about service providers' behavior for customers to recognize their satisfaction/dissatisfaction at service point. According to them, to manage service failure successfully, exact recognition of service problem, an apology, sufficient description about service failure and some tangible compensation are important. Parasuraman, Zeithaml & Malhorta(2005) approached the service recovery from how to measure, rather than how to manage, and moved to on-line market not to off-line, then invented E-RecS-QUAL which is a measuring tool about on-line service recovery. 2.3 Customer Satisfaction The definition of customer satisfaction can be divided into two points of view. First, they approached customer satisfaction from outcome of comsumer. Howard & Sheth(1969) defined satisfaction as 'a cognitive condition feeling being rewarded properly or improperly for their sacrifice.' and Westbrook & Reilly(1983) also defined customer satisfaction/dissatisfaction as 'a psychological reaction to the behavior pattern of shopping and purchasing, the display condition of retail store, outcome of purchased goods and service as well as whole market.' Second, they approached customer satisfaction from process. Engel & Blackwell(1982) defined satisfaction as 'an assessment of a consistency in chosen alternative proposal and their belief they had with them.' Tse & Wilton(1988) defined customer satisfaction as 'a customers' reaction to discordance between advance expectation and ex post facto outcome.' That is, this point of view that customer satisfaction is process is the important factor that comparing and assessing process what they expect and outcome of consumer. Unlike outcome-oriented approach, process-oriented approach has many advantages. As process-oriented approach deals with customers' whole expenditure experience, it checks up main process by measuring one by one each factor which is essential role at each step. And this approach enables us to check perceptual/psychological process formed customer satisfaction. Because of these advantages, now many studies are adopting this process-oriented approach(Yi, 1995). 2.4 Loyalty Intention Loyalty has been studied by dividing into behavioral approaches, attitudinal approaches and complex approaches(Dekimpe et al., 1997). In the early years of study, they defined loyalty focusing on behavioral concept, behavioral approaches regard customer loyalty as "a tendency to purchase periodically within a certain period of time at specific retail store." But the loyalty of behavioral approaches focuses on only outcome of customer behavior, so there are someone to point the limits that customers' decision-making situation or process were neglected(Enis & Paul, 1970; Raj, 1982; Lee, 2002). So the attitudinal approaches were suggested. The attitudinal approaches consider loyalty contains all the cognitive, emotional, voluntary factors(Oliver, 1997), define the customer loyalty as "friendly behaviors for specific retail stores." However these attitudinal approaches can explain that how the customer loyalty form and change, but cannot say positively whether it is moved to real purchasing in the future or not. This is a kind of shortcoming(Oh, 1995). 3. Research Design 3.1 Research Model Based on the objects of this study, the research model derived is shows, Step 1 and Step 2 are significant, and mediation variable has a significant effect on dependent variables and so does independent variables at Step 3, too. And there needs to prove the partial mediation effect, independent variable's estimate ability at Step 3(Standardized coefficient
shows, Step 1 and Step 2 are significant, and mediation variable has a significant effect on dependent variables and so does independent variables at Step 3, too. And there needs to prove the partial mediation effect, independent variable's estimate ability at Step 3(Standardized coefficient
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