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

• Journal of the Korean Society of School Health
• /
• v.7 no.1
• /
• pp.57-71
• /
• 1994

I investigated actual conditions of smoking of teenagers who were randomly chosen middle and high school students. 1. Juvenile smoking 1) Parents' opinions of juvenile smoking Most parents do not want their children to smoke after growth : 88.6% of fathers (middle school students: 88.9%, high school students: 88.4%) and 95.1% of mothers (middle school students: 93.4%, high school students :95.5%). 2) Teenagers' opinions of smoking after growth The rate of students who will smoke after growth is 10.8% (middle school students: 12.0%, high school students: 9.9%): students in agricultural areas show the higher rate than those in cities. 3) Parents' opinions of their children's smoking now 1.5% of fathers want their children to smoke now (middle school students: 1.3%, high school students: 1.6%) and 1.1% of mothers do (middle school students: 0.6%, high school students: 1.5%). This shows that most parents do not want their children to smoke now. 4) Students' opinions of their friends' smoking now Students who want their friends smoke now cover 7.8% (middle school students: 7.1%, high school students: 8.4%). This rates are higher than those of parents shown in (3). And more high school students and more girl students gave the positive reponse than middle school boy and girl students, respectively. 5) Students' views of smoking "Look like an adult" covers the rate of 4.0% (boy: 7.8%, girl:3.6%) 6.7% of middle school students have this view, while 3.7% of high school students have. 16.1% of students had an experience of smoking during the last one year (boy: 29.9%, girl: 8.6%): this shows that the rate of the boy students is more than 3 times greater than that of the girl students and high students who experienced smoking last year covers 20.2%, while middle school students shows 10.9%. 6) Actual conditions of students' smoking The present rate of students' smoking is 22.4% (boy:38.3%, girl:13.8%): the rate of boy students is greater than that of girl students. Students who smoke more than pack of cigarettes a day cover 8.2% (boy: 17.5%, girl: 3.2%): 5.2% of middle school students (boy:11.4%, girl: 2.1%) smoke more than one pack while 10.7% of high school students do (boy:21.5%, girl: 4.2%). This shows that the rate of boy students' smoking is greater than that of girl students' smoking. 7) The rate of smoking of students' parents 75.4% of fathers (city: 74.5%, agricultural area:75.9%) smoke: and more than a half (62.4%) smoke more than a pack cigarettes a day. On the other hand, the rate of smoking mothers is 5.2%(city: 4.3%, agricultural area: 7.3%): the rate is higher in agricultural areas. 8) Opinions of smoking population in the future 61.4% of students answered that smoking population will increase, while 27.0% have the opinion that smoking population will decrease. 2. Opinions of the effects of smoking on health 1) Have you heard that smokers are likely to suffer from tuberclosis? 78.3% of students said yes (boy: 80.8%, girl: 76.4%): it is shown that the rate of boys is greater than that of girls. 2) Have you heard that smokers are likely to get out of endurance? 76.6% of students (boy: 69.3%, girl: 49.7%) answered yes: it is shown that the rate of boys is greater than that of girls. 3) Have you heard that heart-beats get fast when one smokes? 32.5% of students (boy: 35.5%, girl: 30.9%) answered yes: 32.2% in cities(boy: 33.0%, girl: 31.8%) and 33.5% in agricultural areas(boy: 41.8%, girl: 28.8%): and 28.7% middle students and 35.5% of high school students answered yes. 4) Have you heard that smokers are likely to have heart-diseases? 35.1% of students (boy: 34.0%, girl: 34.1%) answered yes: 35.3% in cities (boy: 37.2%, girl: 34.2%) and 36.7% in agricultural areas (boy: 39.0%, girl: 33.9%): 34.8% of middle school students and 35.4% of high school students. 5) Have you heard that smokers are likely to have a lung cancer? 91.4% of students (boy: 93.2%, girl: 89.9%) answered yes: 90.35% in cities and 94.2% in agricultural areas. 6) Have you heard that the life of smokers gets shorter? 94.3% of students (boy:94.6%, girl: 92.2%) answered yes. 7) Have you heard that pregnant smokers will deliver a baby with low birth weight? 29.6% of students (boy: 29.8%, girl: 29.4%) answered yes: the rates of boys and girls almost the same. 8) Have you heard that one feels calm when one smokes? 80.1% of students (boy: 81.8%, girl: 79.2%) answered yes: boys and girls showed almost the same rate. 3. Preventive measures Smoking people continued to increase all over the world because smoking not only mitigated emotional uneasiness such as loneliness, nervousness and so on, but also could be very helpful from the social perspective. This was so because they did not consider harmful effects of smoking on health, and victims. However, because any -one can have physical disorders caused by smoking, people should always keep in mind the following preventive measures. 1) Doctors or teachers should set an example of giving up smoking. Informing patients or students of harmful effects of smoking to persuade their family and relatives not to smoke. 2) Through mass media like newspapers, periodicals or broadcasting, to make people know harmful effects of smoking and not smoke. 3) To prohibit selling teenagers cigarette by law. 4) To prohibit smoking in public places like work places, offices, lecture rooms, recreation rooms, buses, trains and so on. 5) To decrease the rate of life insurance for non-smokers as in foreign countries and to give a warming of the harmful effects on cigarette packets or ads.

• Journal of Oral Medicine and Pain
• /
• v.31 no.4
• /
• pp.297-316
• /
• 2006

The increasing tendency of medical disputes is one of the remarkable social phenomena. Especially we must not overlook the phenomenon that production and circulation of information related to medical accidents is increasing rapidly through the internet. In this research, we evaluated the web sites which provide the information related to medical accidents using the keyword "medical accidents" in March 2006, and classified the 28 web sites according to the kinds of establishers. We also analyzed the contents of the sites, and checked and compared the current status of the web sites and problems that have to be improved. Finally, we suggested the possible solutions to prevent medical accidents. The detailed results were listed below. 1. Medical practitioners, general public, and lawyers were all familiar with and prefer the term "medical accidents" mainly. 2. In the number of sites searched by the keyword "medical accidents", lawyer had the most sites and medical practitioners had the least ones. 3. Many sites by general public and lawyers had their own medical record analysts but there was little professional analysts for dentistry. 4. General public were more interested in the prevention of medical accidents but the lawyers were more interested in the process after medical accidents. The sites by medical practitioners dealt with the least remedies of medical accidents, compared with other sites. 5. General public wanted the third party such as government intervention into the disputes including the medical dispute arbitration law or/and the establishment of independent medical dispute judgment institution. 6. In the comparison among the establishers of web sites, medical practitioners dealt with the least examples of medical accidents. 7. The suggestion of cases in counseling articles related to dental accidents were considered less importantly than the reality. 8. Whereas there were many articles about domestic cases related to the bloody dental treatment, in the open counseling articles the number of dental treatment regarding to non insurance treatment was large. 9. In comparing offered information of medical accidents based on the establishers, general public offered vocabularies, lawyers offered related laws and medical practitioners offered medical knowledge relatively. 10. They all cited the news pressed by the media to offer the current status of domestic medical accidents. Especially among the web sites by general public, NGOs provided the plentiful statistical data related to medical accidents. 11. The web sites that collect the medical accidents were only two. As a result of our research, we found out that, in the flood of information, medical disputes can be occurred by the wrong information from third party, and the medical practitioners have the most passive attitudes on the medical accidents. Thus, it is crucial to have the mutual interchange and exchange of information between lawyer, patients and medical practitioners, so that based on clear mutual comprehension we can solve the accidents and disputes more positively and actively.