• 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 Nutrition and Health
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• v.48 no.5
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• pp.419-428
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• 2015

Purpose: The current study was conducted in order to develop the Korean Healthy Eating Index (KHEI) for assessing adherence to national dietary guidelines and comprehensive diet quality of healthy Korean adults using the 5th Korea National Health and Nutrition Examination Survey (KNHANES) data. Methods: The candidate components of KHEI were selected based on literature reviews, dietary guidelines for Korean adults, 2010 Dietary Reference Intakes for Koreans (2010 KDRI), and objectives of HP 2020. The associations between candidate components and risk of obesity, abdominal obesity, and metabolic syndrome were assessed using the 5th KNHANES data. The expert review process was also performed. Results: Diets that meet the food group recommendations per each energy level receive maximum scores for the 9 adequacy components of the index. Scores for amounts between zero and the standard are prorated linearly. For the three moderation components among the total of five, population probability densities were examined when setting the standards for minimum and maximum scores. Maximum scores for the total of 14 components are 100 points and each component has maximum scores of 5 (fruit intakes excluding juice, fruit intake including juice, vegetable intakes excluding Kimchi and pickles, vegetable intake including Kimchi or pickles, ratio of white meat to read meat, whole grains intake, refined grains intake, and percentages of energy intake from carbohydrate) or 10 points (protein foods intake, milk and dairy food intake, having breakfast, sodium intake, percentages of energy intake from empty calorie foods, and percentages of energy intake from fat). The KHEI is a measure of diet quality as specified by the key diet recommendations of the dietary guidelines and 2010 KDRIs. Conclusion: The KHEI will be used as a tool for monitoring diet quality of the Korean population and subpopulations, evaluation of nutrition interventions and research.

• Childhood Kidney Diseases
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• v.13 no.2
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• pp.161-169
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• 2009

Purpose : This study was performed to report the diagnosis and treatment of nephrotic syndrome manifesting in the first year of life. Methods : We retrospectively reviewed the clinical data with chart review in 7 patients who were diagnosed as nephrotic syndrome manifesting in the first year of life from 1996 to 2007. Results : Three patients had congenital nephrotic syndrome, the other 4 patients had infantile nephrotic syndrome. Their ages ranged from birth to 11 months and male to female ratio was 1 to 6. Renal biopsies were done in 6 patients. One patient had Finnish type congenital nephrotic syndrome, 2 patients had diffuse mesangial sclerosis, 2 patients had focal segmental glomerulosclerosis and 1 patient had minimal change disease. Genetic analyses of NPHS2, PLCE1, and WT1 were done in 4 patients and 2 of them had WT1 mutation. Among 3 patients with congenital nephrotic syndrome, 1 patient was diagnosed as congenital nephrotic syndrome of Finnish type and the other 2 patients were diagnosed as Denys-Drash syndrome. All of the patients with congenital nephrotic syndrome died due to sepsis. Among 4 patients with infantile nephrotic syndrome, 2 patients died and 1 had remission, another patient progressed to end stage renal disease. Conclusion : Most of nephrotic syndrome manifesting in the first year was hereditary renal disease. Patients with nephrotic syndrome manifesting in the 3 month of life had poorer prognosis and needed more aggressive management including early dialysis and renal transplantation might be considered compared with infantile nephrotic syndrome. Further genotype-phenotype correlation studies are needed.

• The Korean Journal of Air & Space Law and Policy
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• v.22 no.1
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• pp.9-27
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• 2007

The purpose of this paper is to study about the legal system of the Inter-governmental Agreement on the International Space Station('IGA') which was signed on Jan 29,1998. This paper is divided into three main parts ; 1) a review of ISS, 2) the principal rules of IGA, 3) the legal system of IGA. First, the paper draws an outline of ISS by dealing with (1) the definition, characteristics, and functions of ISS, (2) the composition of ISS. Second, the paper explains the principal rules of IGA which include (1) the rule of 'Partnership' and (2) the rule of 'Peaceful Purpose'. Third, the legal system of IGA is studied by looking at five different aspects: (1) the registration system, (2) a general jurisdiction, criminal jurisdiction and a control of jurisdiction, (3) intellectual property rights and other rights beside intellectual property, (4) cross-waiver of liability and several elements in compensation of damages, (5) the dispute resolution. IGA contains new contents and applications of legal system which was not included in the former space law. Therefore IGA will work as a model law for international cooperation of space development. It is important for us to study the matter of ISS, because disputes on the ISS are left solely to contracting parties although IGA will regulate overall situations. The renewed IGA is even more important because all the space development is expected to take place on an international cooperation basis. On the basis of this paper, all the important parts of IGA is expected to be further studied so that the research can contribute to the establishment of the legal system of space development in Korea.

• The Korean Journal of Air & Space Law and Policy
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• no.spc
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• pp.17-34
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• 2007

The purpose of this paper is to study about the legal system of the Inter-governmental Agreement on the International Space Station('IGA') which was signed on Jan 29,1998. This paper is divided into three main parts ; 1) a review of ISS, 2) the principal rules of IGA, 3) the legal system of IGA. First, the paper draws an outline of ISS by dealing with (1) the definition, characteristics, and functions of ISS, (2) the composition of ISS. Second, the paper explains the principal rules of IGA which include (1) the rule of 'Partnership' and (2) the rule of 'Peaceful Purpose'. Third, the legal system of IGA is studied by looking at five different aspects: (1) the registration system, (2) a general jurisdiction, criminal jurisdiction and a control of jurisdiction, (3) intellectual property rights and other rights beside intellectual property, (4) cross-waiver of liability and several elements in compensation of damages, (5) the dispute resolution. IGA contains new contents and applications of legal system which was not included in the former space law. Therefore IGA will work as a model law for international cooperation of space development. It is important for us to study the matter of ISS, because disputes on the ISS are left solely to contracting parties although IGA will regulate overall situations. The renewed IGA is even more important because all the space development is expected to take place on an international cooperation basis. On the basis of this paper, all the important parts of IGA is expected to be further studied so that the research can contribute to the establishment of the legal system of space development in Korea.

• Korean Journal of Heritage: History & Science
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• v.44 no.1
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• pp.52-71
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• 2011

This study was initiated with the intent to consider the features of Gugokwonlim and to compare Gabsagugok(甲寺九曲) to Yongsangugok(龍山九曲) against the backdrop of Mt. Gyeryong by revealing their nature and confirming the names and exact locations. A literature review, interviews with local people and field studies confirmed that Gabsagugok and Yongsangugok are each composed of 9 seasonal features. The former is made up of Yongyuso(龍遊沼) - Iilcheon(二一川) - Baengnyonggang(白龍岡) - Dalmuntaek(達門澤) - Geumgyeam(金鷄?) - Myeongwoldam(明月潭) - Gyemyeongam(鷄鳴巖) - Yongmunpok(龍門瀑) - Sujeongbong(水晶峰) while the latter is made up of Simyongmun(尋龍門) - Eunnyongdam(隱龍潭) - Waryonggang(臥龍剛) - Yuryongdae(遊龍臺) - Hwangnyongam(黃龍岩) - Hyeollyongso(見龍沼) - Ullyongtaek(雲龍澤) - Biryongchu(飛龍湫) - Sillyongyeon(神龍淵). Both Gabsagugok and Yongsangugok are part of Gugokwonlim built in the valleys of Mt. Gyeryong in the late Joseon Dynasty by Byeoksu Yun Deok-yeong (1927) and Chwieum Gwon Jun-myeon (1932), respectively, with a 5 year difference. Gabsagugok was supposedly designed to reflect an individual taste for the arts and to admire principles of Juyeok (ch. Zhouyi) and the beauty of nature. On the contrary, Yongsangugok appears to be the builder's expression of his longing for independence day, likened to the life of a dragon after receiving the sad news of Japan's annexation of Korea. Such differences show that these two builders had very different intentions from one another. The letters of Gabsagugok have a semi cursive style and were deeply engraved on the rock in a square shape. Consequently they have not been worn away except for those in Yongyuso, the first Gok. In contrast, the letters in Yongsangugok have an antiquated, cursive-Yija style but because they were engraved relatively lightly, serious wear and damage occurred. In terms of location, Gabsagugok was built around Ganseongjang adjacent to the 5th Gok while Yongsangugok was set up around the 5th Gok, Hwangnyongam. Meanwhile, the important motif which forms the background of Gabsagugok seemingly highlights the geographic identity of Mt. Gyeryong using the dragon and the chicken as themes. It also appears to symbolize the principles of Juyeok focusing on Kan of the Eight Trigrams for divination; this requires an in-depth study for confirmation. The main motif and theme of Yongsangugok is the dragon. It infuses the builder's intentions in Sangsinri Valley by communicating with nature through a story of a dragon's life from birth to ascension. It is assumed that he tried to use this story to express his hope for restoring the national spirit and reconstructing the country.

• Management & Information Systems Review
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• v.38 no.2
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• pp.183-208
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• 2019

The purpose of this study is to examine the effects of the transformational leadership on helping behaviors and deviant behaviors of organizational members and to verify the control effect of value consistency and to suggest a process for effective business management and human resource management. For this purpose, questionnaires were distributed to employees working in office management, area marketing, and manufacturing industries in Seoul, Gyeonggi and Chungcheong provinces, and the final 334 copies were used for empirical analysis. Data were analyzed using SPSS 18.0, and reliability analysis, factor analysis for validity, correlation analysis, and regression analysis were conducted to verify the research hypothesis. The results of the empirical analysis based on the questionnaire based on the object are as follows. First, charisma of transformational leadership showed negative impact on helping behavior, and intellectual stimulation of transformational leadership and individual care showed positive influence on helping behavior. Second, charisma of transformational leadership showed negative influence on deviant behavior, whereas intellectual stimulation of transformational leadership and sub - constitutional factor of individual care did not show significant influence on deviant behavior. Third, as a result of confirming the moderating role of transformational leadership and helping behavior on the level of value consistency, it showed moderating effects on charisma and individual consideration of transformational leadership. Through this study, we proved the effectiveness of transformative leadership which increases the helping behaviors of the members and reduces the deviant behavior. Based on this, we proposed the necessity of developing managers' transformational leadership improvement program to enhance the sustainability of the organization. And we confirmed the partial influence relationship on the adjustment effect of value consistency. In addition, negative influence of charisma suggests a significant point in the management process design.

• Korean Journal of Heritage: History & Science
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• v.55 no.1
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• pp.111-132
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• 2022

The comprehensive examination on tendering system has been introduced to the Cultural Heritage repair and restoration field since 2016 to remedy the repair issues of South Gate in 2014. The Cultural Heritage Administration tried to attain the high performance of the cultural heritage repair and restoration works securing the proper payment for the repair and restoration works. It is high time to review the operating performance of the comprehensive examination on tendering system (hereinafter referred to as the "CEOTS"), as the system has been run for over 5 years to correspond with its original goal, i.e., "The Proper Payment in return for the High Performance of Repair and Restoration works." This study intends to analyze 114 tenders of CEOTS from 2016 to 2020. As a result of the analysis of 114 tenders, firstly, more than half of bid winners were in the top 20% of repair & restoration capacity disclosure amount list, which mostly fulfilled the goal of 'attaining high performance.' Secondly, as the winning bid rate is decreasing from 86.847% in 2017 to 85.488% in 2020, the goal of 'guarantee of a proper payment' is not achieved yet. Thirdly, the influence of Economic Evaluation section in CEOTS has been grown since the change of scoring system in CEOTS in 2019. This study identifies two reasons why the winning bid rate of CEOTS has decreased. Firstly, it is caused by the fact that 'the group that got more than 1st place' and 'the first place group' that are more than half of the total bidders have the decreasing bidding rate trend as the years go by. Secondly, the exclusion rate of 'the group that got more than 1st place' is higher than the exclusion rate of 'the group that got less than 1st place', which means the expected winning rate would be lowered. It is proposed that the revision of CEOTS code is needed, i.e. easing the strict rule concerning the exclusion rate as well as setting up the lower bidding limit to prevent the excessive decreasing winning bid rate.

• Korean small business review
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• v.43 no.4
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• pp.59-93
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• 2021

This study surveyed 413 small business owners who experienced closure to see how the loss perception experienced by small business owners affects their comeback through fear of failure. The analysis results are as follows. First, the larger the received loss of financial capital, market capital, and social capital, the greater the fear of failure. Second, the greater the fear of failure, the less willingness to re-start-up, but it did not affect the willingness to work. Third, perceived loss of financial capital, market capital, and social capital grew fear of failure, which negatively affected the willingness to re-start. However, as for the willingness to work, only the perception of loss to market competitiveness strengthened the willingness to work through fear of failure. This suggests that if you think you are out of business due to market competitiveness, you are more likely to choose to get a job than to start a business. Fourth, those with higher entrepreneurial self-efficiency had less effect of perceived loss on fair of failure than those with lower entrepreneurial loss. In other words, it can be seen that a person with high entrepreneurial self-efficiency is likely to start-up. It is noteworthy that despite the tendency to fail due to market competition and lack of understanding of risks, small business operators were most aware of the loss of social capital. This is presumed to have had the greatest impact on fear of failure because small business owners try to receive funding or business revitalization support through social networks such as acquaintances and relatives. Based on the above results, this study requires sufficient market research to secure a competitive advantage when preparing for start-ups through policy practice suggestions, and suggests ways to reduce financial loss through the establishment of sophisticated business plans.

• Journal of the Korean Society of Marine Environment & Safety
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• v.28 no.6
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• pp.965-972
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• 2022

This is a basic study to establish marine activity criteria based on the seakeeping performance of less than 10-tons fishing vessels. These vessels account for approximately 95% of Korea's currently registered fishing vessels, and accidents and loss of life are also occurring during marine activities such as navigation, and fishing. Accordingly, the Ministry of Oceans and Fisheries has set a regulation of vessel traf ic control to restrict the operation of fishing vessels when the high seas watch takes effect, but it is applied equally without criteria according to the ship ton level and wave height; therefore, many differences may exist in ship fluctuations. Because the fluctuation of the ship owing to the wave height can be a factor in marine accidents by reducing the sense of boarding and performance of equipment, the seakeeping performance must be reviewed during waves to secure safe marine activities such as navigation and fishing. However, the review for the fishing vessel of established marine activity criteria based on the seakeeping performance is insufficient. Accordingly, the seakeeping performance was evaluated for a 10-ton class (G/T 9.77 tons) fishing vessel in Korea, and the level of marine activity according to the significant wave height and ship speed was interpreted by applying the operation and survival of the established seakeeping performance criteria. The analysis results indicated that the roll of the ship exceeded the operation criteria from 0.4m and the survival criteria from 2.2m. The pitch of the ship exceeded the operation criteria from 1.7m and did not exceed the survival criteria until 3.0m. However, the rolling exceeding the survival criteria from 2.2m may not be safe. Therefore, fishing vessels with less than 10-tons can leave before the high seas watch takes effect. However, they did not satisfy the criteria for evaluating the performance of the sea in relation to marine activities. Although this study was limitedly evaluated for 10-ton fishing vessels, it is expected to be of great help in preparing marine activity criteria.