• 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 Intelligence and Information Systems
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• v.26 no.1
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• pp.75-95
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• 2020

With the growth of social networks, various forms of SNS have emerged. Based on various motivations for use such as interactivity, information exchange, and entertainment, SNS users are also on the fast-growing trend. Facebook is the main SNS channel, and companies have started using Facebook pages as a public relations channel. To this end, in the early stages of operation, companies began to secure a number of fans, and as a result, the number of corporate Facebook fans has recently increased to as many as millions. from a corporate perspective, Facebook is attracting attention because it makes it easier for you to meet the customers you want. Facebook provides an efficient advertising platform based on the numerous data it has. Advertising targeting can be conducted using their demographic characteristics, behavior, or contact information. It is optimized for advertisements that can expose information to a desired target, so that results can be obtained more effectively. it rethink and communicate corporate brand image to customers through contents. The study was conducted through Facebook advertising data, and could be of great help to business people working in the online advertising industry. For this reason, the independent variables used in the research were selected based on the characteristics of the content that the actual business is concerned with. Recently, the company's Facebook page operation goal is to go beyond securing the number of fan pages, branding to promote its brand, and further aiming to communicate with major customers. the main figures for this assessment are Facebook's 'OK', 'Attachment', 'Share', and 'Number of Click' which are the dependent variables of this study. in order to measure the outcome of the target, the consumer's response is set as a key measurable key performance indicator (KPI), and a strategy is set and executed to achieve this. Here, KPI uses Facebook's ad numbers 'reach', 'exposure', 'like', 'share', 'comment', 'clicks', and 'CPC' depending on the situation. in order to achieve the corresponding figures, the consideration of content production must be prior, and in this study, the independent variables were organized by dividing into three considerations for content production into three. The effects of content material, content structure, and message styles on Facebook's user behavior were analyzed using regression analysis. Content materials are related to the content's difficulty, company relevance, and daily involvement. According to existing research, it was very important how the content would attract users' interest. Content could be divided into informative content and interesting content. Informational content is content related to the brand, and information exchange with users is important. Interesting content is defined as posts that are not related to brands related to interesting movies or anecdotes. Based on this, this study started with the assumption that the difficulty, company relevance, and daily involvement have an effect on the dependent variable. In addition, previous studies have found that content types affect Facebook user activity. I think it depends on the combination of photos and text used in the content. Based on this study, the actual photos were used and the hashtag and independent variables were also examined. Finally, we focused on the advertising message. In the previous studies, the effect of advertising messages on users was different depending on whether they were narrative or non-narrative, and furthermore, the influence on message intimacy was different. In this study, we conducted research on the behavior that Facebook users' behavior would be different depending on the language and formality. For dependent variables, 'OK' and 'Full Click Count' are set by every user's action on the content. In this study, we defined each independent variable in the existing study literature and analyzed the effect on the dependent variable, and found that 'good' factors such as 'self association', 'actual use', and 'hidden' are important. Could. Material difficulties', 'actual participation' and 'large scale * difficulties'. In addition, variables such as 'Self Connect', 'Actual Engagement' and 'Sexual Sexual Attention' have been shown to have a significant impact on 'Full Click'. It is expected that through research results, it is possible to contribute to the operation and production strategy of company Facebook operators and content creators by presenting a content strategy optimized for the purpose of the content. In this study, we defined each independent variable in the existing research literature and analyzed its effect on the dependent variable, and we could see that factors on 'good' were significant such as 'self-association', 'reality use', 'concernal material difficulty', 'real-life involvement' and 'massive*difficulty'. In addition, variables such as 'self-connection', 'real-life involvement' and 'formative*attention' were shown to have significant effects for 'full-click'. Through the research results, it is expected that by presenting an optimized content strategy for content purposes, it can contribute to the operation and production strategy of corporate Facebook operators and content producers.

• Radiation Oncology Journal
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• v.15 no.2
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• pp.137-143
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• 1997

Purpose : Radiation pneumonitis is one of the complications caused by radiation therapy that includes a Portion of the lung tissue. The severity of radiation induced pulmonary dysfunction depends on the irradiated lung volume, total dose, dose rate and underlying Pulmonary function. It also depends on whether chemotherapy is done or not. The irradiated lung volume is the most important factor to predict the pulmonary dysfunction in breast cancer Patients following radiation therapy. There are some data that show the irradiated lung volume measured from CT scans as a part of treatment Planning with the tangential beams. But such data have not been reported in Korea. We planned to evaluate the irradiated lung volume quantitatively using CT scans for the breast tangential field and search for useful factors that could Predict the irradiated lung volume Materials and Methods : The lung volume was measured for 25 patients with breast cancer irradiated with tangential field from Jan.1995 to Aug.1996. Parameters that can predict the irradiated lung volume included; (1) the peruendicular distance from the Posterior tangential edge to the posterior part of the anterior chest wall at the center of the field (CLD) ; (2) the maximum perpendicular distance from the posterior tangential field edge to the posterior Part of the anterior chest wall (MLD) ; (3) the greatest perpendicular distance from the Posterior tangential edge to the posterior part of anterior chest wall on CT image at the center of the longitudinal field (GPD) ; (4) the length of the longitudinal field (L). The irradiated lung volume(RV), the entire both lung volume(EV) and the ipsilateral lung volume(IV) were measured using dose volume histogram. The relationship between the irradiated lung volume and predictors was evaluated by regression analysis. Results :The RV is 61-279cc (mean 170cc), the RV/EV is $2.9-13.0\%\;(mean\;5.8\%)$ and the RV/IV is $4.9-29.0\%\;(mean\;12.2\%)$. The CLD, the MLD and the GPD ave 1.9-3.3cm, 1.9-3.3cm and 1.4-3.1cm respectively. The significant relations between the irradiated lung volume such as RV. RV/EV, RV/IV and parameters such as CLD, MLD, GPO, L. $CLD\timesL,\;MLD\timesL\;and\;GPD\timesL$ are not found with little variances in parameters. The RV/IV of the left breast irradiation is significantly larger than that of the right but the RV/EVS do not show the differences. There is no symptomatic radiation pneumonitis at least during 6 months follow up. Conclusion : The significant relationship between the irradiated lung volume and predictors is not found with little variation on parameters. The irradiated lung volume in the tangential held is liss than $10\%$ of entire lung volume when CLO is less than 3cm. The RV/IV of the left tangential field is larger than that of the right but there was no significant differences in RV/EVS. Symptomatic radiation pneumonitis has not occurred during minimum 6 months follow up.

• KDI Journal of Economic Policy
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• v.12 no.2
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• pp.3-49
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• 1990

This paper analyzes U.S. demand for imports from Asian NIEs and Japan, utilizing the Almost Ideal Demand System (AIDS) developed by Deaton and Muellbauer, with an emphasis on the effect of changes in the exchange rate. The empirical model assumes a two-stage budgeting process in which the first stage represents the allocation of total U.S. demand among three groups: the Asian NIEs and Japan, six Western developed countries, and the U.S. domestic non-tradables and import competing sector. The second stage represents the allocation of total U.S. imports from the Asian NIEs and Japan among them, by country. According to the AIDS model, the share equation for the Asia NIEs and Japan in U.S. nominal GNP is estimated as a single equation for the first stage. The share equations for those five countries in total U.S. imports are estimated as a system with the general demand restrictions of homogeneity, symmetry and adding-up, together with polynomially distributed lag restrictions. The negativity condition is also satisfied for all cases. The overall results of these complicated estimations, using quarterly data from the first quarter of 1972 to the fourth quarter of 1989, are quite promising in terms of the significance of individual estimators and other statistics. The conclusions drawn from the estimation results and the derived demand elasticities can be summarized as follows: First, the exports of each Asian NIE to the U.S. are competitive with (substitutes for) Japan's exports, while complementary to the exports of fellow NIEs, with the exception of the competitive relation between Hong Kong and Singapore. Second, the exports of each Asian NIE and of Japan to the U.S. are competitive with those of Western developed countries' to the U.S, while they are complementary to the U.S.' non-tradables and import-competing sector. Third, as far as both the first and second stages of budgeting are coneidered, the imports from each Asian NIE and Japan are luxuries in total U.S. consumption. However, when only the second budgeting stage is considered, the imports from Japan and Singapore are luxuries in U.S. imports from the NIEs and Japan, while those of Korea, Taiwan and Hong Kong are necessities. Fourth, the above results may be evidenced more concretely in their implied exchange rate effects. It appears that, in general, a change in the yen-dollar exchange rate will have at least as great an impact, on an NIE's share and volume of exports to the U.S. though in the opposite direction, as a change in the exchange rate of the NIE's own currency $vis-{\grave{a}}-vis$ the dollar. Asian NIEs, therefore, should counteract yen-dollar movements in order to stabilize their exports to the U.S.. More specifically, Korea should depreciate the value of the won relative to the dollar by approximately the same proportion as the depreciation rate of the yen $vis-{\grave{a}}-vis$ the dollar, in order to maintain the volume of Korean exports to the U.S.. In the worst case scenario, Korea should devalue the won by three times the maguitude of the yen's depreciation rate, in order to keep market share in the aforementioned five countries' total exports to the U.S.. Finally, this study provides additional information which may support empirical findings on the competitive relations among the Asian NIEs and Japan. The correlation matrices among the strutures of those five countries' exports to the U.S.. during the 1970s and 1980s were estimated, with the export structure constructed as the shares of each of the 29 industrial sectors' exports as defined by the 3 digit KSIC in total exports to the U.S. from each individual country. In general, the correlation between each of the four Asian NIEs and Japan, and that between Hong Kong and Singapore, are all far below .5, while the ones among the Asian NIEs themselves (except for the one between Hong Kong and Singapore) all greatly exceed .5. If there exists a tendency on the part of the U.S. to import goods in each specific sector from different countries in a relatively constant proportion, the export structures of those countries will probably exhibit a high correlation. To take this hypothesis to the extreme, if the U.S. maintained an absolutely fixed ratio between its imports from any two countries for each of the 29 sectors, the correlation between the export structures of these two countries would be perfect. Therefore, since any two goods purchased in a fixed proportion could be classified as close complements, a high correlation between export structures will imply a complementary relationship between them. Conversely, low correlation would imply a competitive relationship. According to this interpretation, the pattern formed by the correlation coefficients among the five countries' export structures to the U.S. are consistent with the empirical findings of the regression analysis.

• Journal of the Korean Society of Groundwater Environment
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• v.7 no.3
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• pp.103-115
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• 2000

The formation of brown-colored precipitates is one of the serious problems frequently encountered in the development and supply of groundwater in Korea, because by it the water exceeds the drinking water standard in terms of color. taste. turbidity and dissolved iron concentration and of often results in scaling problem within the water supplying system. In groundwaters from the Pajoo area, brown precipitates are typically formed in a few hours after pumping-out. In this paper we examine the process of the brown precipitates' formation using the equilibrium thermodynamic and kinetic approaches, in order to understand the origin and geochemical pathway of the generation of turbidity in groundwater. The results of this study are used to suggest not only the proper pumping technique to minimize the formation of precipitates but also the optimal design of water treatment methods to improve the water quality. The bed-rock groundwater in the Pajoo area belongs to the Ca-$HCO_3$type that was evolved through water/rock (gneiss) interaction. Based on SEM-EDS and XRD analyses, the precipitates are identified as an amorphous, Fe-bearing oxides or hydroxides. By the use of multi-step filtration with pore sizes of 6, 4, 1, 0.45 and 0.2 $\mu\textrm{m}$, the precipitates mostly fall in the colloidal size (1 to 0.45 $\mu\textrm{m}$) but are concentrated (about 81%) in the range of 1 to 6 $\mu\textrm{m}$in teams of mass (weight) distribution. Large amounts of dissolved iron were possibly originated from dissolution of clinochlore in cataclasite which contains high amounts of Fe (up to 3 wt.%). The calculation of saturation index (using a computer code PHREEQC), as well as the examination of pH-Eh stability relations, also indicate that the final precipitates are Fe-oxy-hydroxide that is formed by the change of water chemistry (mainly, oxidation) due to the exposure to oxygen during the pumping-out of Fe(II)-bearing, reduced groundwater. After pumping-out, the groundwater shows the progressive decreases of pH, DO and alkalinity with elapsed time. However, turbidity increases and then decreases with time. The decrease of dissolved Fe concentration as a function of elapsed time after pumping-out is expressed as a regression equation Fe(II)=10.l exp(-0.0009t). The oxidation reaction due to the influx of free oxygen during the pumping and storage of groundwater results in the formation of brown precipitates, which is dependent on time, $Po_2$and pH. In order to obtain drinkable water quality, therefore, the precipitates should be removed by filtering after the stepwise storage and aeration in tanks with sufficient volume for sufficient time. Particle size distribution data also suggest that step-wise filtration would be cost-effective. To minimize the scaling within wells, the continued (if possible) pumping within the optimum pumping rate is recommended because this technique will be most effective for minimizing the mixing between deep Fe(II)-rich water and shallow $O_2$-rich water. The simultaneous pumping of shallow $O_2$-rich water in different wells is also recommended.