• The Journal of Small Business Innovation
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• v.20 no.1
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• pp.1-18
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• 2017

This study examined whether divided and spun-off companies design and execute spin-offs to minimize tax burdens by analyzing multiple spin-off transactions in the Dongbu Group, when the Korean tax law regarding corporate restructuring was amended in July 2010. Before the July 2010 tax amendment, taxes on the capital gains arising from the qualifying spin-off were deferred to the earlier of the shares in or assets acquired by the spun-off company are disposed. This tax treatment relieves the divided company's tax burden by deferring taxes on capital gains, compared with non-qualifying spin-offs. However, if shares in or assets acquired by the spun-off company are disposed after the July 2010 tax amendment, the capital gain incurred at the time of the qualifying spin-off would be taxed again at the spun-off company, in addition to a taxation on the divided company's capital gains. This creates double taxation implications for the parties involved in the spin-off. As a result, the double taxation may outweigh the benefit from the tax deferral on the qualifying spin-off, which may make a qualifying spin-off tax unfavorable. Among the four spin-off cases in the Dongbu Group addressed in this study, a spin-off occurred before the tax amendment, whereas three spin-offs occurred after the tax amendment. Initially, we expected that the spin-off before the tax amendment would be a qualifying spin-off, and the other three spin-offs would be non-qualifying spin-offs, considering the taxation rules before and after the July 2010 tax amendment. However, based on the review of summarized balance sheets disclosed in the spin-offs' corporate filings, no capital gains arose during the four spin-offs that occurred in the Dongbu Group. Therefore, we concluded that the Dongbu Group considered non-tax factors more than tax factors while designing and executing the spin-offs. The local media posited during this period that these spin-offs may intend to resolve financial issues in the Dongbu Group, and this analysis was supported by the fact that some shares in the new spun-off companies were sold by the Dongbu Group. Our case studies provide evidence that all costs, including both tax and non-tax costs, must be considered in the course of spin-offs, in addition to the tax burdens on all parties involved in the corporate restructuring, which parallels the work of Scholes et al. (2008). This study provides implications that various aspects should be considered and reviewed in advance when the management makes decisions for effective tax planning.

• Tuberculosis and Respiratory Diseases
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• v.43 no.2
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• pp.190-200
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• 1996

Background : Mechanical ventilation constitutes the last therapeutic method for acute respiratory failure when oxygen therapy and medical treatment fail to improve the respiratory status of the patient. This invasive ventilation, classically administered by endotracheal intubation or by tracheostomy, is associated with significant mortality and morbidity. Consequently, any less invasive method able to avoid the use of endotracheal ventilation would appear to be useful in high risk patient. Over recent years, the efficacy of nasal mask ventilation has been demonstrated in the treatment of chronic restrictive respiratory failure, particularly in patients with neuromuscular diseases. More recently, this method has been successfully used in the treatment of acute respiratory failure due to parenchymal disease. Method : We assessed the efficacy of Bilevel positive airway pressure(BiPAP) in the treatment of acute exacerbation of chronic obstructive pulmonary disease(COPD). This study prospectively evaluated the clinical effectiveness of a treatment schedule with positive pressure ventilation via nasal mask(Respironics BiPAP device) in 22 patients with acute exacerbations of COPD. Eleven patients with acute exacerbations of COPD were treated with nasal pressure support ventilation delivered via a nasal ventilatory support system plus standard treatment for 3 consecutive days. An additional 11 control patients were treated only with standard treatment. The standard treatment consisted of medical and oxygen therapy. The nasal BiPAP was delivered by a pressure support ventilator in spontaneous timed mode and at an inspiratory positive airway pressure $6-8cmH_2O$ and an expiratory positive airway pressure $3-4cmH_2O$. Patients were evaluated with physical examination(respiratory rate), modified Borg scale and arterial blood gas before and after the acute therapeutic intervention. Results : Pretreatment and after 3 days of treatment, mean $PaO_2$ was 56.3mmHg and 79.1mmHg (p<0.05) in BiPAP group and 56.9mmHg and 70.2mmHg (p<0.05) in conventional treatment (CT) group and $PaCO_2$ was 63.9mmHg and 56.9mmHg (p<0.05) in BiPAP group and 53mmHg and 52.8mmHg in CT group respectively. pH was 7.36 and 7.41 (p<0.05) in BiPAP group and 7.37 and 7.38 in cr group respectively. Pretreatment and after treatment, mean respiratory rate was 28 and 23 beats/min in BiPAP group and 25 and 20 beats/min in CT group respectively. Borg scale was 7.6 and 4.7 in BiPAP group and 6.4 and 3.8 in CT group respectively. There were significant differences between the two groups in changes of mean $PaO_2$, $PaCO_2$ and pH respectively. Conclusion: We conclude that short-term nasal pressure-support ventilation delivered via nasal BiPAP in the treatment of acute exacerbation of COPD, is an efficient mode of assisted ventilation for improving blood gas values and dyspnea sensation and may reduce the need for endotracheal intubation with mechanical ventilation.

• International Commerce and Information Review
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• v.13 no.3
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• pp.169-201
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• 2011

There was a new wave in grocery business with development of information and technology, thus a movement from traditional stores to online stores, In order to expand the scale of traditional supermarket and to satisfy the customers' needs, they provide offline and online services simultaneously. This paper is based on the previous studies which had been researched in developed countries from late 1990s to early 2000s and the purpose of this study is to introduce the idea and operation system of e-Grocery business. Moreover, we suggest the alternatives on delivery service methods in order to satisfy the customers' needs through analyzing the current condition of e-Grocers in Korea. According to the result of this study, Korean e-Grocers offer only attended home delivery services. In our opinion, Korean supermarkets have to take hybrid model which Tesco.com is using. There are some alternatives to increase the profits of Korean e-Grocers and to provide better services to their customers as follows: As an alternatives for delivery services, picking service is the easiest and cheapest way to apply for supermarkets. This is very useful for working women and also it is possible to order by smartphone recently. They can order the goods to the closest local supermarkets from working place, and then they pick them up on the way home from working off. In order to improve the quality of delivery services, to use the reception box will be the way to provide better services to the customers. The reception box is a way to protect the quality of goods such as fresh-cut product, which require the freshness through the temperature adjustment, and also to keep the safety of ordered goods through locking system Through this system, supermarkets are able to use attended or unattended services under the customers' satisfaction. However, using the reception box is expensive, so shared reception box will be an alternative. As an alternative for development of e-Grocery business, the advertisement for e-Grocery business has to be supported in order to attract potential customers in e-Grocery business. Furthermore, the main concerns of e-Grocery business such as the sanitation and safety of goods, and convenience must be guaranteed in order to keep the loyal customers and to attract new customers.

• Journal of Chest Surgery
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• v.40 no.4 s.273
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• pp.288-291
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• 2007

Background: Myxoma makes up close to 50% of adult primary cardiac tumors, and this mainly occurs in the left atrium, and rarely in the right atrium or ventricle. The patients clinically present with symptoms of hemodynamic obstruction, embolization or constitutional changes. Diagnosis is currently established most appropriately with 2-D echocardiography. Surgical resection of myxoma is a safe and effective treatment, Material and Method: We reviewed our clinical experience in the diagnosis and management of 57 cases of cardiac myxoma that were seen over a 20-year period from July 1984 to July 2004. Result: The mean age of the patients was $53.5{\pm}14.0$ years (range: 12 to 76 years). There were 38 (67%) females and 19 (33%) males. The preoperative symptoms included dyspnea on exertion in 27 patients, palpitation in 4, chest pain in 9 and syncopal episode in 4. The diagnosis was made by echocardiography alone in 51, and by combination of echocardiography, CT and angiography in 6. The tumor attachment sites were the interatrial septum in 50, the mital valve annulus in 3 and the left atrial wall in cases, The tumor was excised successfully via biatriotomy in 33 (58%), left atriotomy in 15 (26%), the septal approach via right atriotomy in 3, Inverted T incision in 3 and the extended septal approach in 3. The follow-up time ranged from 1 to 229 months (mean follow-up: $84.0{\pm}71.3$ months). There were no early and late deaths and no recurrence during the follow-up period except for follow-up loss in 5 patients. Conclusion: It's concluded that excision of cardiac myxoma is curative and the long-term survival is excellent. Immediate surgical treatment was indicated because of the high risk of embolization or of sudden cardiac death. Radical tumor excision may prevent recurrences.

• Journal of Korea Port Economic Association
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• v.34 no.4
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• pp.191-208
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• 2018

This paper focuses on the integration aspect of operators to determine an improvement strategy for the operating system to enhance competitiveness of Busan Port. This Study proposes the following alternatives: valuation standards for the integration of operators, the road map for the integration period, the scope and role setting of integrated operators' participation of Busan Port Authority(BPA), and the separation and linkage North Port and the New Port operators. First, the valuation standards for operator integration should be based on international standards. Additionally quantitative factors such as financial situation, business performance and participating companies' profitability, and the qualitative factors such as management ability, technology, and labor relations should be considered. Second, the timing of North Port's operator integration should be prioritized in the short term in conjunction with the commencement of its phase 2-4, 2-5, and 2-6. The integration of New Port operators should provide a road map for a relatively long-term perspective. Third, the participation of BPA' integrated operators should be considered in terms of publicity as a policy coordinator between terminals and by pursuing the profitability of entering into overseas business by fostering Korean global terminal operators. The scope and role of participation ensures that the experience and technology of the terminal operation business is maximized. Fourth, because physically intergrating the North Port' operator into a single corporate form is difficult, initially establishing a special purpose company to maximize the effect of the integrated operation is necessary. Then, the operators decided to convert to a holding company given the termination of the lease term contract with the State or BPA, and ultimately proposed a merger into a single corporation.