• 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.

• The Korean Journal of Elementary Counseling
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• v.10 no.2
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• pp.185-201
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• 2011

The purpose of this study is to reveal and confirm the factor structure inherent in the Korean inventory of peer relationships(KIPR; Sang-Hwang Hong, et al., 2009) in order to strengthen the interpretive usefulness of the test. For this purpose, the inventory was administered to the total of 616 children in the fourth through sixth grades in three elementary schools located in Gyungnam area, and the data from 578 of them were analyzed. The results of the study can be summarized as follows. First, as a result of the exploratory factor analysis of 3-factor and 4-factor models, the 3-factor model was found to be more appropriate. In the 3-factor model, the factor 1 is named "Lack of Self-Confidence and Social Withdrawal" as it consists of such circumplex scale items as Non-Assertiveness (C5), Social Avoidance (C4), the Cold (C3), and Too Submissive (C6). The factor 2 is named "Too Aggressive and Controlling" and consists of items Too Controlling (C1) and Hard to be Supportive (C2). The factor 3 is named "Too Caring" and consists of items Too Responsible (C7), Over Involvement (C8), and Too Submissive (C6). Second, as a result of the confirmatory factor analysis, the 3-factor model, in comparison to the 4-factor model, was found to better reflect the collected data(RMSEA=.054), its goodness of fit was not satisfactory but within the acceptable range(CFI=.786), and its power of simplicity and clarity was also adequate(PCFI=.733). In the current study, through the exploratory and confirmatory factor analyses of scores from the Korean inventory of peer relationships circumplex scales, scales within the peer relationship circumplex model that are near each other and are highly correlated were confirmed to be grouped together as same factors. I believe the main merit of the study lies in the above result having provided the necessary foundation for forming the superordinate and representative scale that encompasses the eight circumplex scales, which enhances the test's interpretive usefulness.

• Journal of Agricultural Extension & Community Development
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• v.21 no.2
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• pp.1-28
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• 2014

Private consulting firms that are currently participating in rural area development projects with a bottom-up approach are involved in nearly all areas of rural area development, and the policy environment that emphasizes the bottom-up approach will further expand their participation. Reviews of private consulting firms, which started out with high expectations in the beginning, are now becoming rather negative. Expertise is the key issue in the controversy over private consulting firms, and the analysis tends to limit the causes of the problems within firms. This study was conducted on the premise that the fixation on cause and structure results in policy issues in the promotion process. That is because the government authorities are responsible for managing and supervising the implementation of policies, not developing the policies. The current issues with consulting firms emerged because of the hasty implementation of private consulting through the government policy trend without sufficient consideration, as well as the policy environment that demanded short-term outcomes even though the purpose of bottom-up rural area development lies in the ideology of endogenous development focused on the changes in residents' perceptions. Research was conducted to determine how the problems of private consulting firms that emerged and were addressed in this context influenced the consulting market, using current data and based on the firms' business performance. In analyzing the types, firms were divided into three groups: top performers including market leaders (9), excellent performers (36), and average performers (34). An analysis of the correlation between the business performance of each type and managerial resources such as each firm's expertise revealed that there was only a correlation between human resources and regional development in excellent performers, and none was found with the other types. These results imply that external factors other than a firm's capabilities (e.g., expertise) play a significant role in the standards of selecting private consulting firms. Thus, government authorities must reflect on their error of hastily adopting private consulting firms without sufficient consideration and must urgently establish response measures.

• The Journal of Fisheries Business Administration
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• v.19 no.2
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• pp.1-58
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• 1988

The purpose of this study is to investigate the relation between social education and secondary education of seaside and sea village schools for supporting the successors to fishery. Objects of the study were five groups; 321 fishermen, 107 staff members of a Fishery Guidance Center, 1, 001 students, 306 teachers of sea villages, 193 staff members of a Fishery Cooperative Association. The total number of people being object of this study was 1, 876 persons. The questionaire used for this study was made after preliminary counseling with fishermen in sea villages and teachers in seaside schools. The results of this study are as follow ; 1) About the value of Fishery and successors to Fishery There have been more positive responses than negative ones to the question on the value of fishery. The main reason for positive responses lies in the potentiality for development of fishery but the negative responses are because of the heavy work. 56.8% of the respondents expected an increasing number of successor to fishery, but 43.2% of the respondents had a negative foresight on that problem. The negative respondents stated that the fisherman that moved from the sea villages to the urban areas are responsible for the none increasing numbers of successors to fishery. Most of the respondents answered that government support is needed in order to increase the number of successors to fishery. 2) Social education for Fishermen Only 40% of fishermen know the Fishing Village Guidance Center as the main institute for social education. 94.17% of the respondents prefer plural institutes to single ones. 5.9% of the respondents answered with opposit opinions. 40.4% of the respondents answered that technical teachings has not often been practised. The reason why technical teaching does not often come into effect are as follows; lack of technical expertise, insufficient concern of staff members of the Guidance Center or the Cooperation Association. Also fishermen answered that the Fisherman Guidance Center does not often practise technical education. The Fishery Cooperation Association with its social education for fisherman takes the role of education for the economical way and carries out financial assistance. The relationship between the Fishery Cooperative Association and fishermen is presented satisfactory. However, the frequency of education is not satisfactory. Indifferences between staff members of the Fishery Cooperative Association does not carry out fishery education very often. Also loaned money matters were not satisfactory. 3) Secondary education for Fishery This study showed that it is desirable that the practical course of middle schools in islets and seaside villages take education on fishery ; however, a few schools only take the practical course fishery. Most of the fishery high schools want computer education as a new recommendable course. The students of fishery high schools want computer education as a new recommendable course. The students of fishery high schools have problems with scientific terms in the text books for the practical of fishery high schools have problems with scientific terms in the text books for the practical courses. Over 80% of the respondents agreed that the principals of schools in islets and sea side villages should be men having majored in fishery. 4) The connection between social education and secondary education for fishery a. It is desirable that the principal and vice principal of secondary schools in islets and sea side villages are men majored in fishery. b. It is recommendable that fishery courses are taken as practical courses in fishery village schools for it is helpful to relate between the vocation and the district's special character, as well as to built up relation between the middle school education and the fishery high school education. c. The teachers of fishery high schools and the officials of government offices which are related to fishery should work together to realize a program on teaching various kinds of techniques and give other useful informations to fishermen. d. During the vacations the fishery high school could be used for the social education of fishermen. Seminars on fishery technique and cultural aspects could be held. Especially a spiritual education which is needed for the improvement of the society of fishermen could be achieved by a cultural education. e. On the state level a financial support to raise the number of successors to fishery, a national policy for the betterment of the life of fishermen, as well as active publicity activities are necessary. f. A financial support of the government for raising the number of the successors to fishery is needed. For this purpose a fishery education performed on a state level would be desirable.

• Journal of the Korean Institute of Traditional Landscape Architecture
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• v.31 no.1
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• pp.28-37
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• 2013

As a symbolic landscape of Seoul, Namsan has undergone not only physical changes but also changes in its human use and characteristics. At this point, research on Namsan, which holds diverse stories that have accumulated over a long period, as a cultural landscape is necessary. In particular, a concrete understanding of the characteristics of the mountain's use in the period of its initiation as a modern park is an important task in research on the history of urban parks. Consequently, the purpose of the present study lies in grasping the use of Namsan at the time of the establishment of Kyongsungbu Namsan Park Design Proposal in 1917 and examining the characteristics per space. The research process was based on the status of the park design plan. The primary source of information came from the analysis of historical newspaper articles. Additional materials including documents, old maps, photographs, postcard materials were also used. The period of the study was 1883 to 1917. This time was the initial period of Namsan Park soon after the opening up of Korea's ports to the world. The major spaces in which Namsan was used as a park encompassed Hanyang Park, Waeseongdae Park, Noin-jeong, Jangchung-dan, and remaining parts of Namsan in a natural state. When the main ways in which each space is used are examined based on the data analyzed, Namsan has been used for purposes including public events, accidents, religious worship, track and field days, field trips, and strolls. When the nature of each of the spaces is determined in terms of the characteristics of their use, these spaces were characterized as community parks, outdoor community spaces, indoor community spaces, sports arenas, and natural parks, among other things. The present study is significant in terms of research on the history of parks for confirming that Namsan in the initial period already served as a modern park for urban activities and grasping the specific urban activities that were engaged in on Namsan.

• Journal of Chest Surgery
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• v.29 no.10
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• pp.1081-1089
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• 1996

Pulmonary atresia with intact ventricular septum has continued to have a high surgical mortality and morbidity. This mAy attribute to the non-uniformity of the anomaly. We reviewed a total of 34 infants with pulmonary atresla and intact ventricular septum managed in this hospital between 1987 and 1995. Mean age and body weight were 57.2 (range, 3-208) days and 4.1 (range, B.3∼6.8) kg. The preoperative Z-value of the diameter of the tricuspid valve was less than -2 in 85.2% of patients and less than -4 in 33. 3% . It is well correlated w th right ventricular cavity size (n=27. r10.68, p< 0.05). Coronary artery-right ventricular fistulas were identified in 3 patients, and right ventricular dependency was suspected in 1 Over All hospital mortality was 23.5%(8/34), although it decreased to 16.6%(4124) in 1990s. Subsequent procedures were performed in 6 patients between 3 days and 58 months after Initial palliation : one bidirectional cavopulmonary shunt and 1 Fontan operation after systemic-pulmonary shunt, 3 transannular patch + atrial septal defect closure and 1 additional systemic-pulmonary shunt after polmonary valvectomy or valvotomy. Changes of Z-values of the diameter of tricuspid valve have been followed up in 11 patients between 1 and 66 months postoperatively. Z-values were increased In 5 out of 8 transannular right ventriculAr outflow tract enlargement group and in 1 out of 3 pulmonary valvectomy or valvotomy group. Our data suggest that tailoring a treatment to right ventricular cavity size and coronary anom lies may improve the surgical outcome. A Z-value of the tricuspid valve diameter could be used.

• Korean Journal of Poultry Science
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• v.15 no.2
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• pp.81-91
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• 1988

The purpose of this research is to analyze the tendencies of poultry consumption in Korea. The information used is the data collected three times during the period from Sept. 1, 1985 to April 30, 1987 throughout the major cities. Those who participated in the survey are 2, 598 including housewives, nutritionists, cookers, group feeding institutions, woman's organizations, and the students of doing nutrition－related studies. Consumer preferences for poultry meat and eggs tend to move toward high quality and more strict sanitary standards. Following this line of consumer preference changes, the poultry product marketing supported by cold chain system is rapidly developing. Household consumption of poultry meat largely consists of hi－and semi－broilers but the household demand for these two broilers tends to decrease steadily over time. In general poultry meat consumption appears to be affected by consumer taste rather than market factors such as prices. In addition consumer choices are quite different depending on poultry meat parts which are preferred in order of drum sticks, wings, and breasts. In particular drum sticks are most preferred than any other parts. An important problem in poultry production is related to consumption seasonality since large part of poultry meat consumption is concentrated during the summer season. Another problem is associated with little development of cooking methods. At present there are two types of primary commercial cooking techniques, fries and samgaetang (boiled chicken with jinsang and rice). For promoting domestic poultry meat disposal and reducing the demand seasonality, new cooking methods should be developed and followed by more aggresive advertisements. In domestic egg trade, smaller packing units(i.e., 10 eggs per unit) tend to bi preferred to large ones (i.e., 30 eggs per unit). In consumers egg purchasing decisions nearness to the shops and convenience appear to be important factors. For egg shell colors consumers recognize that there is no difference in nutritional values. However, survey results show that consumers highest preference lies in eggs with brown color. Eggs are most popular among children and preferred in order of middle－and high－school students, 17-25 age people, and adults. Egg prices are concieved relatively cheap to its nutritional values. In house－holds eggs are consumed in the forms of fries, side dishes, and lunch basket dishes. However, high level of cholesterol content in eggs appears to be an important problem in promoting eggs consumption.

• Management & Information Systems Review
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• v.33 no.1
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• pp.191-217
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• 2014

The Purpose of this study is to find the effect factors of R&D investment in SMEs which plays an important role in the national economy, and the differences of the effect factors by the type of SMEs. The subject of this study is about 3,400 SMEs mentioned in "The survey of technical statistics on SMEs in 2007" by Korea Federation of Small and Medium Business. The effect factors are related with the size of business, the infrastructure of R&D and the activities of R&D which have been studied by many researchers. The methods of analysis are regression analysis, moderating effect analysis and the software package used is SPSS 12.0. The results of the study are as fallow. First, it was found that unlike in previous studies which show the effect of the elements of business's size, research infrastructure, research activities on R&D investment, one element alone can't be considered for meaningful result but the various elements have effect on R&D investment at the same time. In other words, the number of employees and the sales as the elements of business's size, the ratio of researchers, the technical ability, the ratio of equipment possession and the intellectual properties as the elements of R&D infrastructure, the activity of ideas and joint research as the elements of R&D activities have positive(+) effect, whereas the participation of CEO in the activity of R&D as the elements of R&D activities activity has negative(-) one. The number of employees, the ratio of researchers, and the sales had relatively high influence whereas equipment possession, technical ability, intellectual properties, the participation of CEO in the research, the activity of idea, joint research had relatively low influence. Next, it was also found that there are differences of the effect factors over the types of SMEs. SMEs were classified into 19 types by eight criteria such as start-ups and existing business by business age; small business and medium business by size; manufacturing business and service business by product type;independent business and subcontractor business by dealing type; businesses in the entering, growing, maturing and restructuring stage by growth stage; businesses with low, medium and high technology by technological level; pioneering business and non-pioneering business by industrial type; and businesses with state-of-the-art technology and non-advanced business by the level of business activities. The meaning of this study lies in the fact that it found the various effect factors should be considered at the same time when conducting study on SMEs' R&D investment, and the differences by the type should be acknowledged. This study surpassed the limitations of the previous studies which focused on a couple of factors and types. This study result can also be considered for other studies on achievement, organization, marketing and others. Moreover, it shows that a differential policy by business type is needed when formulating SME policy.

• Journal of the Korean association of regional geographers
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• v.7 no.1
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• pp.83-95
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• 2001

The purpose of this study is to examine that we can estimate land use by land values in 5 great cities. For this purpose, I calculated the percentage that each lot value makes up of the highest land values in the city as a indicator. I think this rate is very useful in the comparative study about many cities. At first, I set up four hypotheses based on my preceding studies. Hypothesis 1, the range of CBD can be estimated as having about 10% of the peak land values. Hypothesis 2, when the peak rate of concentric circle of land values seperated from CBD circle is about 30% of the peak land values, that is sub-CBD. Hypothesis 3, generally, a lot of having about 5% of the peak land values represents residential land commercial land use. Hypothesis 4, a lot of having about 3% of the peak land values represents only residential land use. The data on land values in five great cities were got from public notification on land values(1999) of the Ministry of Construction & Transportation. I selected highest lot values from many standard lot value in each Tong(the minimum administrative unit) in each cities. And I drew land values isopleth. Through that isopleth, I identified CBD cmd sub-CBD. Through the book of public notification on land values, I identified what land use are lots of having over 10%, about 5%, below 3% of the peak land values. As a result, we identified land use can be estimated by the percentage that each lot value makes up of the highest land values in the city. The bigger urban size becomes and the more stable land use becomes, the higher fitness of hypotheses becomes. The lowest degree of fitness about 4 hypotheses among 5 great cities showed in Inchon. Because Inchon lies adjacent to the greatest Seoul. The percentage that showed the lowest degree of fitness is 5% of the highest land values. The land use on lots of having about 5% of the peak land values is different from each other according to regional character in city.

• Journal of the Korea Academia-Industrial cooperation Society
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• v.8 no.6
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• pp.1634-1647
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• 2007

"To invest or not to invest?" Most business leaders are frequently faced with this question on new and ongoing projects. The challenge lies in deciding what projects to choose, expand, contract, defer, or abandon. The project valuation tools used in this process are vital to making the right decisions. Traditional tools such as discounted cash flow (DCF)/net present value (NPV) assume a "fixed" path ahead, but real world projects face uncertainties, forcing us to change the path often. Comparing to other traditional valuation methods, the real options approach captures the flexibility inherent to investment decisions. The use of real options has gained wide acceptance among practitioners in a number of several industries during the last few decades. Even though the options are present in all types of business decisions, it is still not considered as a proper method of valuation in some industries. Mining has been comparably slow to adopt new valuation techniques over the years. The reason fur this is not entirely clear. One possible reason is the level and types of risks in mining. Not only are these risks high, but they are also more numerous and involve natural risks compared with other industries. That is why the purpose of this study is to deal with a more practical approach to project valuation, known as real options analysis in mining industry. This paper provides a case study approach to the copper mining industry using a real options analysis. It shows how companies can minimize investment risks, exercise flexibility in decision making and maximize returns.