• 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 Journal of Industrial Distribution & Business
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• v.8 no.6
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• pp.51-60
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• 2017

Purpose - This study aimed to investigate the correlation between the social activity of the elderly and recognition of family cohesion of the elderly who are exposed to the current aging society. In addition, the study has delved into the method of family cohesion improvement through the differences between groups based on the mediator effect of how the results have effects on the elderly's self-control capabilities. Research design, data, and methodology - This study has targeted the elderly who are attending the elderly university among users in seven community centers located in Seoul and Gyeonggi-do area. The study has also conducted a survey by the format of a half-structured questionnaire. It is aiming to investigate the elderly's family cohesion with children and their self-control capability, and understand their satisfaction of social activity to help successful elderly life. The study has suggested the following as mentioned. First, the study analyzed that the perceptual factor of family cohesion with children would be deducted based on advanced researches. Second, the influencing relationship would be analyzed through the relational analysis between the elderly's family cohesion and social activity. Results - The family cohesion with children has a significant effect on psychological happiness and it showed the influencing relationship with improvement of the elderly's self-control capability. Therefore, creating fellowship through meaningful conversation with children would be needed. In addition, various programs and consultant service would be offered to build healthy relationship between aged parents and their children. Through this, the elderly will be able to have not only better relationships with their family, but also increased psychological health and well-being as well. Conclusions - It is needed that not only supporting policies for children who take care of aged parents but also that the elderly who need long-term care could meet their children whenever they want through increased numbers of sanatoriums operated by cities and countries. In addition, the nation would offer financial and administrative support continuously so that people receive the benefits from sanatoriums located in the locality of children's residence beyond the elderly's residence. Moreover, social infra would be established as well.

• Journal of Environmental Impact Assessment
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• v.24 no.6
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• pp.607-618
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• 2015

Five years have passed since the first set of environmental samples was taken in 2011 to represent various ecosystems which would help future generations lead back to the past environment. Those samples have been preserved cryogenically in the National Environmental Specimen Bank(NESB) at the National Institute of Environmental Research. Even though there is a strict regulation (SOP, standard operating procedure) that rules over the whole sampling procedure to ensure each sample to represent the sampling area, it has not been put to the test for the validation. The question needs to be answered to clear any doubts on the representativeness and the quality of the samples. In order to address the question and ensure the sampling practice set in the SOP, many steps to the measurement of the sample, that is, from sampling in the field and the chemical analysis in the lab are broken down to evaluate the uncertainty at each level. Of the 8 species currently taken for the cryogenic preservation in the NESB, pine tree samples from two different sites were selected for this study. Duplicate samples were taken from each site according to the sampling protocol followed by the duplicate analyses which were carried out for each discrete sample. The uncertainties were evaluated by Robust ANOVA; two levels of uncertainty, one is the uncertainty from the sampling practice, and the other from the analytical process, were then compiled to give the measurement uncertainty on a measured concentration of the measurand. As a result, it was confirmed that it is the sampling practice not the analytical process that accounts for the most of the measurement uncertainty. Based on the top-down approach for the measurement uncertainty, the efficient way to ensure the representativeness of the sample was to increase the quantity of each discrete sample for the making of a composite sample, than to increase the number of the discrete samples across the site. Furthermore, the cost-effective approach to enhance the confidence level on the measurement can be expected from the efforts to lower the sampling uncertainty, not the analytical uncertainty. To test the representativeness of a composite sample of a sampling area, the variance within the site should be less than the difference from duplicate sampling. For that, a criterion, ${i.e.s^2}_{geochem}$(across the site variance) <${s^2}_{samp}$(variance at the sampling location) was proposed. In light of the criterion, the two representative samples for the two study areas passed the requirement. In contrast, whenever the variance of among the sampling locations (i.e. across the site) is larger than the sampling variance, more sampling increments need to be added within the sampling area until the requirement for the representativeness is achieved.

• The Korean Journal of Air & Space Law and Policy
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• v.23 no.2
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• pp.137-172
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• 2008

The earliest safety data programs, the FDR and CVR, were electronic reporting systems that generate data "automatically." The FDR program, originally instituted in 1958, had no publicly available restrictions for protections against sanctions by the FAA or an airline, although there are agreements and union contracts forbidding the use of FDR data for FAA enforcement actions. This FDR program still has the least formalized protections. With the advent of the CVR program in 1966, the precursor to the current FAR 91.25 was already in place, having been promulgated in 1964. It stated that the FAA would not use CVR data for enforcement actions. In 1982, Congress began restricting the disclosure of the CVR tape and transcripts. Congress added further clarification of the availability of discovery in civil litigation in 1994. Thus, the CVR data have more definitive protections in place than do FDR data. The ASRS was the first non-automatic reporting system; and built into its original design in 1975 was a promise of limited protection from enforcement sanctions. That promise was further codified in an FAR in 1979. As with the CVR, from its inception, the ASRS had some protections built in for the person who might have had a safety problem. However, the program did not (and to this day does not) explicitly deal with issues of use by airlines, litigants, or the public media, although it appears that airlines will either take a non-punitive stance if an ASRS report is filed, or the airline may ignore the fact that it has been filed at all. The FAA worked with several U.S. airlines in the early 1990s on developing ASAP programs, and the FAA issued an Advisory Circular about the program in 1997. From its inception, the ASAP program contained some FAA enforcement protections and company discipline protections, although some protection against litigation disclosure and public disclosure was not added until 2003, when FAA Order 8000.82 was promulgated, placing the program under the protections of FAR 193, which had been added in 2001. The FOQA program, when it was first instituted through a demonstration program in 1995, did not contain protections against sanctions. Now, however, the FAA cannot take enforcement action based on FOQA safety data, and an airline is limited to "corrective action" under the program. Union contracts can exclude FOQA from the realm of disciplinary action, although airline practice may be for airlines to require retraining if there is no contract in place forbidding it. The data is protected against disclosure for litigation and public media purposes by FAA Order 8000.81, issued in 2003, which placed FOQA under the protections of FAR 193. The figure on the next page shows when each program began, and when each statute, regulation, or order became effective for that program.

• Journal of the Korean Applied Science and Technology
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• v.35 no.4
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• pp.1108-1119
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• 2018

As the interest on the air pollution is gradually rising at home and abroad, automotive and fuel researchers have been studied on the exhaust and greenhouse gas emission reduction from vehicles through a lot of approaches, which consist of new engine design, innovative after-treatment systems, using clean (eco-friendly alternative) fuels and fuel quality improvement. This research has brought forward two main issues : exhaust emissions (regulated and non-regulated emissions, PM particle matter) and greenhouse gases of vehicle. Exhaust emissions and greenhouse gases of automotive had many problem such as the cause of ambient pollution, health effects. In order to reduce these emissions, many countries are regulating new exhaust gas test modes. Worldwide harmonized light-duty vehicle test procedure (WLTP) for emission certification has been developed in WP.29 forum in UNECE since 2007. This test procedure was applied to domestic light duty diesel vehicles at the same time as Europe. The air pollutant emissions from light-duty vehicles are regulated by the weight per distance, which the driving cycles can affect the results. Exhaust emissions of vehicle varies substantially based on climate conditions, and driving habits. Extreme outside temperatures tend to increasing the emissions, because more fuel must be used to heat or cool the cabin. Also, high driving speeds increases the emissions because of the energy required to overcome increased drag. Compared with gradual vehicle acceleration, rapid vehicle acceleration increases the emissions. Additional devices (air-conditioner and heater) and road inclines also increases the emissions. In this study, three light-duty vehicles were tested with WLTP, NEDC, and FTP-75, which are used to regulate the emissions of light-duty vehicles, and how much emissions can be affected by different driving cycles. The emissions gas have not shown statistically meaningful difference. The maximum emission gas have been found in low speed phase of WLTP which is mainly caused by cooled engine conditions. The amount of emission gas in cooled engine condition is much different as test vehicles. It means different technical solution requires in this aspect to cope with WLTP driving cycle.