• 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.

• Management & Information Systems Review
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• v.38 no.1
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• pp.1-21
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• 2019

This study focuses on (1) the relationship between the network intensity of top managers and the R&D investment of Korean firms, and (2) the moderating effects of the type (related-division vs. unrelated-division) and system (physical division vs. spin-offs) of corporate division on this relationship. The sample of this study was all type and/or system of corporate division implemented by Korean firms during 18-years (1999-2016) study periods. The results of multiple regression analyses as follow. First, as was expected in hypothesis 1 the network intensity of top managers has a strong positive linear relation with the R&D investment of Korean firms. Second, regarding the moderating effect of division type the results show that related-divisions significantly intensify the positive relationship of the network intensity of top managers with the R&D of Korean firms although unrelated-divisions did not. Third, in the analysis of moderating effect of corporate division system the results present the stronger positive moderating effect of spin-offs rather than physical divisions. The findings of the study implies that strong network intensity of top managers can be beneficial to long-term decision such as R&D investment of Korean firms. They accords to network theory that emphasize the importance of strong network effect among top managers based on their trust. The findings also implies that researchers and practitioners should consider organizational-level factors such as organizational structure, culture, corporate governance, etc as well as individual-level factors such as the characteristics and relationships of organizational members when making the decision for firm.

• Proceedings of the Korea Water Resources Association Conference
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• 2023.05a
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• pp.256-256
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• 2023

집중호우는 전 세계적으로 큰 기후변화 문제 중 하나다. 극심한 집중호우의 빈도수는 지구 온난화로 인해 지난 세기 중반 이후부터 점차 증가하고 있으며 그로인한 인적 및 물적인 피해 또한 증가하고 있다. 이러한 손상을 방지하기 위해서는 적절한 설계 홍수량을 계산하는 것이 중요하다. 최근에는 미계측지역의 유출량 추정 시 분포형 강우-유출 모델을 이용한다. 분포형 모델의 가장 큰 장점은 소유역의 분할 과정을 거칠 필요 없이 유역에서 무작위 점의 유출을 시뮬레이션 할 수 있다는 것이다. 본 연구에서는 2000년 11월 니스에 발생했던 강우를 기반으로 Var 유역의 소유역이자 미계측 지역인 프랑스 니스의 Ubac Vallone의 유출량 및 유출계수를 지형 데이터 등의 물리적 인자와 분포형 강우-유출모델인 MIKE SHE를 이용하여 추정하였다. 또한, 입력되는 인자의 상대적 중요성을 파악하기 위해 민감도 분석을 수행하였다. 본 연구에서는 각 인자에 대한 상대민감도 분석을 바탕으로, 유출량에 상대적으로 큰 영향을 미치는 인자를 제안하였다. 연구 결과, 50년, 100년 및 162년 빈도별 확률강우량에 따른 유출량을 추정하였으며, 162년의경우 총 유출량은 124,384.8m³, 최대 유출량 1.512m³/s, 유출계수 0.53으로 나타났다. 총 유출량과 첨두유량에 대한 상대 민감감도 분석 결과, 수리전도도가 1.5로 첨두유량과의 민감도가 높게 나타났으며, 대수층의 수평방향 수리전도도는 0.48로 총 유출량과의 민감도가 높게 나타났다