• 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 Preventive Medicine and Public Health
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• v.22 no.1 s.25
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• pp.125-135
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• 1989

This paper was carried out to study on correlation between mentally retardation and lead and zinc. The subjects were 297 mentally retarded children: 132 of Bomyung special school and Sunmyung, which were located in Taegu city of Korea. The former had their parents but the latter had not. The control group 63 children were randomly seleted from the Dong-in primary school near to Medical School of Kyungpook National University. Atomic absorption spectrophotometer, model IL-551 connected with CTF atomizer(IL. 655) was used for the analysis of lead and zinc. The mean value of lead in hair of mentally retarded children was $14.97{\pm}3.71ppm$ which is significantly higher than that of control group, $11.36{\pm}2.83ppm$. But the content of zinc was not significant in both groups. In the lead there was no significant correlation to age but significant negative correlation to IQ. Zinc showed significant correlation to age but not to IQ. Among the handicapped children, no signigicant correlation between orphan group and non orphan group. Handicaps of mentally-retarded children were speech impairment, emotional disturbance, double and triple handicaps, sensory impairment and abnormal dietary patterns. There were significantly higher contents of lead compared with normal group, except the latter two groups. The disease conditions of mentally retarded children were mongolism, autism, cerebral palsy, epilepsy and microcephaly. In comparing with mongolism, significant difference were existent only on the cerebral palsy and group of unknown etiology. We attempted to divide their past history into external etiology and internal etiology, but could not find significant difference. In view of the whole results, the relationship between mentally-retarded children and lead was presumed to be the early time exposure rather than long interval exposure during growth and the contact opportunity was considered important subject in maternal and child health care.

• Journal of Yeungnam Medical Science
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• v.23 no.1
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• pp.26-35
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• 2006

Background: Luteolin, a flavone found in various Chinese herbal medicines is known to possess anti-inflammatory properties through its ability to inhibit various proinflammatory signaling pathways including NF-${\kappa}B$ and p38 MAPK. In this study, we investigated the potential therapeutic effect of luteolin on dextran sodium sulfate (DSS)-induced colitis. Materials and Methods: We used a transgenic mouse model expressing the enhanced green fluorescent protein (EGFP) under the transcriptional control of NF-${\kappa}B$ $cis$-elements. C57BL/6 NF-${\kappa}B^{EGFP}$ mice received 2.5% DSS in their drinking water for six days in combination with daily luteolin administration (1mg/kg body weight, 0.1ml vol, intragastric) or vehicle. NF-${\kappa}B$ activity was assessed macroscopically with a Charge-Coupled Device (CCD) camera and microscopically by confocal analysis. Results: A significant increase in the Disease Activity Index (DAI), histological score (p<0.05), IL-12 p40 secretion in colonic stripe culture (p<0.05) and EGFP expression was observed in luteolin and/or DSS-treated mice compared to water-treated mice. Interestingly, a trend toward a worse colitis (DAI, IL-12p40) was observed in luteolin-treated mice compared to non-treated DSS-exposed mice. In addition, EGFP expression (NF-${\kappa}B$ activity) strongly increased in the luteolin-treated mice compared to control mice. Confocal microscopy showed that EGFP positive cells were primarily lamina propria immune cells. Conclusions: These results suggest that luteolin is not a therapeutic alternative for intestinal inflammatory disorders derived for primary defects in barrier function. Thus, therapeutic intervention targeting these signaling pathways should be viewed with caution.

• Korean Journal of Culture and Social Issue
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• v.11 no.2
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• pp.143-181
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• 2005

This article examines factors that influence health and quality of life. In addition to the symptomatology and physiological functioning, the influence of the psychological functioning and interpersonal relationship on the overall health and quality of life are also investigated. Using a case-study approach, a total of 70 patients suffering from allergy or asthma were interviewed using a semi-structured questionnaire developed by the present authors. It assessed the following six areas: Cause and onset of illness, psychological functioning, health management, trust, social support received and overall health and quality of life. Based on the transactional model (Bandura, 1997; Kim & Park, 2005), the results of the case studies have been integrated and divided into three aspects: (1) Cause and onset of illness that includes physiological and environment factors; (2) mediating influences that includes psychological functioning, health management, interpersonal relationship and social support received; and (3) outcome factor that includes symptomatology, health and quality of life. The psychological functioning includes self-efficacy (self-regulated efficacy, efficacy for enlisting social support, efficacy for managing the environment, and efficacy for overcoming difficulties), positive outlook, life goals, experience of stress, and proxy control. Interpersonal relationship includes trust of family members and the physician. Health management includes receiving proper health assessment, following the advice and prescription given by the physicians, control of the environment and maintaining a healthy lifestyle. The results indicate that physiological, psychological, relational and environment factors interact with each other and affect individual's overall health and quality of life. Self-efficacy, social support received from family members, trust of physicians, and the health care system are key factors promoting healthy lifestyle and quality of life. The results indicate the need for further interdisciplinary, indigenous and cultural psychological research.

• Applied Chemistry for Engineering
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• v.8 no.4
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• pp.560-567
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• 1997

A new approach to obtain stable $W_1/O/W_2$ multiple emulsions has been studied ; The basis of the interfacial interaction between a PCL-PEO-PCL triblock copolymer and a lipophilic emulsifier in the dispersed oil phase was examined. $W_1/O/W_2$ multiple emulsions were prepared by the two-step method. Arlacel P-l35 was used as a liphophilic emulsifier and Synperonic PE/F 127 as a hydrophilic one. Eutanol-G was used as an oil phase. NaCl was encapsulated within the multiple emulsion droplets as the internal marker and its release rate studies were carried out. The suability of the multiple emulsions have been assessed by measuring Separation Ratios(%) and microscopic observations. The release of NaCl was significantly reduced in $W_1/O/W_2$ multiple emulsions containing PCL-PEO-PCL triblock copolymer(2k-4k-2k or 6k-4k-6k) in the oil phase. It may be concluded that the copolymer and the emulsifier form effective interfacial complex to enhance stability and to control the release rate. The effective diffusion coefficients of the NaCl were estimated as $2.64{\times}10^{-15}s$and $3.23{\times}10^{-16}gcm^2/s$ for the $W_1/O/W_2$ multiple emulsion containing 1.2 wt % of PCL-PEO-PCL triblock copolymers with compositions of 2k-4k-2k and 6k-4k-2k, respectively. The rate of release decreased with the increase of the initial concentration of NaCl. The results were examined in view of Higuchi mechanism. A kinetic model which is similar to the model for release of dispersed drugs from a polymeric matrix was found to be suitable for the release of NaCl from $W_1/O/W_2$ multiple emulsions.

• Korean small business review
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• v.31 no.2
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• pp.103-120
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• 2009

As business incubation centers (BICs) have been operating for more than 10 years in Korea, many early stage startups tend to use the services provided by the incubating centers. BICs in Korea have accumulated the knowledge and experience in the past ten years and their services have been considerably improved. The business incubating service has three facets : (1) business infrastructure service, (2) direct service, and (3) indirect service. The mission of BICs is to provide the early stage entrepreneurs with the incubating service in a limited period time to help them grow strong enough to survive the fierce competition after graduating from the incubation. However, the incubating services sometimes fail to foster the independence of new startup companies, and raise the dependence of many companies on BICs. Thus, the dependence on BICs is a very important factor to understand the survival of the incubated startup companies after graduation from BICs. The purpose of this study is to identify the main factors that influence the firm's dependence on BICs and to characterize the relationships among the identified factors. The business incubating service is a core construct of this study. It includes various activities and resources, such as offering the physical facilities, legal service, and connecting them with outside organizations. These services are extensive and take various forms. They are provided by BICs directly or indirectly. Past studies have identified various incubating services and classify them in different ways. Based on the past studies, we classify the business incubating service into three categories as mentioned above : (1) business infrastructure support, (2) direct support, and (3) networking support. The business infrastructure support is to provide the essential resources to start the business, such as physical facilities. The direct support is to offer the business resources available in the BICs, such as human, technical, and administrational resources. Finally, the indirect service was to support the resource in the outside of business incubation center. Dependence is generally defined as the degree to which a client firm needs the resources provided by the service provider in order to achieve its goals. Dependence is generated when a firm recognizes the benefits of interacting with its counterpart. Hence, the more positive outcomes a firm derives from its relationship with the partner, the more dependent on the partner the firm must inevitably become. In business incubating, as a resident firm is incubated in longer period, we can predict that her dependence on BICs would be stronger. In order to foster the independence of the incubated firms, BICs have to be able to manipulate the provision of their services to control the firms' dependence on BICs. Based on the above discussion, the research model for relationships between dependence and its affecting factors was developed. We surveyed the companies residing in BICs to test our research model. The instrument of our study was modified, in part, on the basis of previous relevant studies. For the purposes of testing reliability and validity, preliminary testing was conducted with firms that were residing in BICs and incubated by the BICs in the region of Gwangju and Jeonnam. The questionnaire was modified in accordance with the pre-test feedback. We mailed to all of the firms that had been incubated by the BICs with the help of business incubating managers of each BIC. The survey was conducted over a three week period. Gifts (of approximately ₩10,000 value) were offered to all actively participating respondents. The incubating period was reported by the business incubating managers, and it was transformed using natural logarithms. A total of 180 firms participated in the survey. However, we excluded 4 cases due to a lack of consistency using reversed items in the answers of the companies, and 176 cases were used for the analysis. We acknowledge that 176 samples may not be sufficient to conduct regression analyses with 5 research variables in our study. Each variable was measured through multiple items. We conducted an exploratory factor analysis to assess their unidimensionality. In an effort to test the construct validity of the instruments, a principal component factor analysis was conducted with Varimax rotation. The items correspond well to each singular factor, demonstrating a high degree of convergent validity. As the factor loadings for a variable (or factor) are higher than the factor loadings for the other variables, the instrument's discriminant validity is shown to be clear. Each factor was extracted as expected, which explained 70.97, 66.321, and 52.97 percent, respectively, of the total variance each with eigen values greater than 1.000. The internal consistency reliability of the variables was evaluated by computing Cronbach's alphas. The Cronbach's alpha values of the variables, which ranged from 0.717 to 0.950, were all securely over 0.700, which is satisfactory. The reliability and validity of the research variables are all, therefore, considered acceptable. The effects of dependence were assessed using a regression analysis. The Pearson correlations were calculated for the variables, measured by interval or ratio scales. Potential multicollinearity among the antecedents was evaluated prior to the multiple regression analysis, as some of the variables were significantly correlated with others (e.g., direct service and indirect service). Although several variables show the evidence of significant correlations, their tolerance values range between 0.334 and 0.613, thereby demonstrating that multicollinearity is not a likely threat to the parameter estimates. Checking some basic assumptions for the regression analyses, we decided to conduct multiple regression analyses and moderated regression analyses to test the given hypotheses. The results of the regression analyses indicate that the regression model is significant at p < 0.001 (F = 44.260), and that the predictors of the research model explain 42.6 percent of the total variance. Hypotheses 1, 2, and 3 address the relationships between the dependence of the incubated firms and the business incubating services. Business infrastructure service, direct service, and indirect service are all significantly related with dependence (β = 0.300, p < 0.001; β = 0.230, p < 0.001; β = 0.226, p < 0.001), thus supporting Hypotheses 1, 2, and 3. When the incubating period is the moderator and dependence is the dependent variable, the addition of the interaction terms with the antecedents to the regression equation yielded a significant increase in R2 (F change = 2.789, p < 0.05). In particular, direct service and indirect service exert different effects on dependence. Hence, the results support Hypotheses 5 and 6. This study provides several strategies and specific calls to action for BICs, based on our empirical findings. Business infrastructure service has more effect on the firm's dependence than the other two services. The introduction of an additional high charge rate for a graduated but allowed to stay in the BIC is a basic and legitimate condition for the BIC to control the firm's dependence. We detected the differential effects of direct and indirect services on the firm's dependence. The firms with long incubating period are more sensitive to indirect service positively, and more sensitive to direct service negatively, when assessing their levels of dependence. This implies that BICs must develop a strategy on the basis of a firm's incubating period. Last but not least, it would be valuable to discover other important variables that influence the firm's dependence in the future studies. Moreover, future studies to explain the independence of startup companies in BICs would also be valuable.

• Journal of Nuclear Fuel Cycle and Waste Technology(JNFCWT)
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• v.8 no.4
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• pp.319-327
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• 2010

A nuclear plant ESF ACS simulator was designed, built, and verified to perform experiment related to ESF ACS of nuclear power plants. The dimension of 3D CAD model was based on drawings of the main control room(MCR) of Yonggwang units 5 and 6. The CFD analysis was performed based on the measurement of the actual flow rate of ESF ACS. The air flowing in ACS was assumed to have $30^{\circ}C$ and uniform flow. The flow rate across the HEPA filter was estimated to be 1.83 m/s based on the MCR ACS flow rate of 12,986 CFM and HEPA filter area of 9 filters having effective area of $610{\times}610mm^2$ each. When MCR ACS was modeled, air flow blocking filter frames were considered for better simulation of the real ACS. In CFD analysis, the air flow rate in the lower part of the active carbon adsorber was simulated separately at higher than 7 m/s to reflect the measured value of 8 m/s. Through the CFD analyses of the ACSes of fuel building emergency ventilation system, emergency core cooling system equipment room ventilation cleanup system, it was confirmed that all three EFS ACSes can be simulated by controlling the flow rate of the simulator. After the CFD analysis, the simulator was built in nuclear grade and its reliability was verified through air flow distribution tests before it was used in main tests. The verification result showed that distribution of the internal flow was uniform except near the filter frames when medium filter was installed. The simulator was used in the tests to confirm the revised contents in Reg. Guide 1.52 (Rev. 3).

• Korean Journal of Poultry Science
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• v.41 no.2
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• pp.99-104
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• 2014

The objective of this study is to analyze the production of extra-large egg and assess the impacts of exogenous factors in feeding the layer chicken. The main results of this study are as follows; First, feeding rations on the basics of statistics, internal maximum and minimum temperature and, the age at first egg affect the production of extra-large egg. Second, implicating the standardized coefficients from the conclusion of regression model estimating suggest that the amount of feed has the greatest impact on production followed by the age at first egg. Third, by using the elasticity of output and the volatility in the production, the result suggest that among the independent variable factors in the external volatility, the biggest one goes to feed ration, and the age at first egg follows. In order to control the production volatility in the extra-large egg production of the farms, it is necessary to manage an efficient feeding based on feed ration, age at first egg and, the maximum and minimum temperature inside the farm. Taken together, the results demonstrates that it should be concentrated by controlling the exogenous factors affecting extra large egg production and the management system construct, to increase extra-large egg production and the income of farmers at the same time.

• Journal of Preventive Medicine and Public Health
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• v.35 no.3
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• pp.245-254
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• 2002

Objective : To test if the intake of $H_2$ receptor antagonists ($H_2$-RAs) increases the risk of gastric cancer in the elderly. Methods : The source population for this study was drawn from the responders to a questionnaire survey administered to the Korea Elderly Pharmacoepidemiological Cohort (KEPEC), who were beneficiaries of the Korean Medical Insurance Corporation, were at least 65 years old, and residing in Busan in 1999. The information on $H_2$-RAs exposure was obtained from a drug prescription database compiled between inn. 1993 and Dec. 1994. The cases consisted of 76 gastric cancer patients, as confirmed from the KMIC claims data, the National Cancer Registry and the Busan Cancer Registry. The follow-up period was from Jan. 1993 to Dec. 1998. Cancer free controls were randomly selected by 1:4 individual matching, which took in to consideration the year of birth and gender. Information on confounders was collected by a mail questionnaire survey. The odds ratios, and their 95% confidence intervals, were calculated using a conditional logistic regression model. Results : After adjusting for a history of gastric ulcer symptoms, medication history, and body mass index, the adjusted OR (aOR) was 4.6 (95% CI=1.72-12.49). The odds ratio of long term use (more than 7 days) was 2.3 (95% CI=1.07-4.82). The odds ratio of short term use was 4.6 (95% CI=1.26-16.50). The odds ratio of parenteral use was 4.4 195% CI=1.16-17.05) and combination use between the oral and parenteral routes (aOR, 16.8; 95% CI=1.21-233.24) had the high risk of gastric cancer. The aOR of cimetidine was 1.7 (95% CI=1.04-2.95). The aOR of ranitidine was 2.0 (95% CI=1.21-3.40). The aOR of famotidine was 1.7 (95% CI=0.98-2.80). Conclusion : The intake of $H_2$-RAs might increase the risk of gastric cancer through achlorhydria in the elderly.

• The Southeast Asian review
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• v.28 no.1
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• pp.21-51
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• 2018

This article takes several approaches in explaining recent developments in Vietnam. First, it draws upon an array of sources that idealize Vietnam's embrace of capitalism and integration into the global market in order to sketch out its economy's progress in 2017. Second, it observes, evaluates, and diagnoses recent changes in the Vietnamese economy in the medium to long term by incorporating conflicting perspectives on Vietnam's performance as a capitalist country. Third, this article traces the power shifts that have risen from internal struggles in the Communist Party over political and social issues. Fourth, it elaborates on the aforementioned impact that foreign relations have had on socio-political developments in Vietnam, as well as the government's response. In so doing, it also attempts to evaluate, however briefly, the significance of the 25th anniversary of South Korea-Vietnam relations. Finally, it examines the public's reaction to the post-reform transitions in light of recent sociocultural changes. 2017 was a memorable year for Vietnam: a continuous march toward capitalism; the resulting expansion of the Vietnamese people's demands; political controversies and government control; the looming instability of United States-China relations and various attempts to address the situation. These events will inevitably replicate themselves in the future as the ostensibly socialist Vietnam adopts a capitalist model. The problem is that it is unclear whether these experiences will continue with the consent of the people of socialist Vietnam or engender resistance. It is difficult to achieve meaningful consent in the status quo of worsening inequalities, widespread corruption, monopoly on power, and sustained use of unskilled low-wage workers. In other words, when concerns such as welfare, public health, and the environment are set aside in favor of economic development and commercialization as they have been, discontent, rather than consent, will prevail. It is thus important to keep a watchful eye on the viability of the nominal economic growth, surface-level political stability, and strategic responses to foreign relations that took place in 2017.