• THE INTERNATIONAL COMMERCE & LAW REVIEW
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• v.46
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• pp.351-380
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• 2010

Multinational Enterprises set the prices for transactions between affiliates based principally on their global interest. But the customs authority in Korea wants to set the arm's length price as high as possible to get higher dutiable value for customs purpose, while the internal tax authority in Korea prefers lower arm's length price to get higher value for corporation tax purpose by cutting costs. Problem caused by the inconsistent valuation methods on the same imported goods of the two tax authorities is the single most important tax issue facing multinational enterprises. In the meantime, the customs authority in Korea has thought that it is a universal trend worldwide for the Customs and Internal tax authorities to adopt different methods of valuation on transfer prices between related parties, so KCS couldn't accept APA prices. But the internal tax authority in Korea has taken the initiative in APA program so NTS provided taxpayer with safe-harbor. Recently, KCS created the Advance Customs Valuation Arrangement(ACVA) provisions in the 2008 revision bill of the Customs Act through benchmarking APAs program. Can APAs work for customs? Neither WCO or OECD presents any recommendation on the integration of the valuation methods, but calls for close cooperation between two authorities, which still leaves taxpayers very unstable. We will start to seek ways to integrate the customs valuation and transfer pricing in this study.

• Steel and Composite Structures
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• v.38 no.5
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• pp.497-521
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• 2021

In this study, an effective numerical method is introduced for nonlinear inelastic analyses of rectangular concrete-filled steel tubular (CFST) frames for the first time. A steel-concrete composite fiber beam-column element model is developed that considers material, and geometric nonlinearities, and residual stresses. This is achieved by using stability functions combined with integration points along the element length to capture the spread of plasticity over the composite cross-section along the element length. Additionally, a multi-spring element with a zero-length is employed to model the nonlinear semi-rigid beam-to-column connections in CFST frame models. To solve the nonlinear equilibrium equations, the generalized displacement control algorithm is adopted. The accuracy of the proposed method is firstly verified by a large number of experiments of CFST members subjected to various loading conditions. Subsequently, the proposed method is applied to investigate the nonlinear inelastic behavior of rectangular CFST frames with fully rigid, semi-rigid, and hinged connections. The accuracy of the predicted results and the efficiency pertaining to the computation time of the proposed method are demonstrated in comparison with the ABAQUS software. The proposed numerical method may be efficiently utilized in practical designs for advanced analysis of the rectangular CFST structures.

• Structural Engineering and Mechanics
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• v.75 no.6
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• pp.747-769
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• 2020

This paper provides a semi-analytical approach to investigate the variations of 3D displacement components, electric potential, stresses, electric displacements and transverse vibration frequencies in laminated piezoelectric composite plates based on the scaled boundary finite element method (SBFEM) and the precise integration algorithm (PIA). The proposed approach can analyze the static and dynamic responses of multilayered piezoelectric plates with any number of laminae, various geometrical shapes, boundary conditions, thickness-to-length ratios and stacking sequences. Only a longitudinal surface of the plate is discretized into 2D elements, which helps to improve the computational efficiency. Comparing with plate theories and other numerical methods, only three displacement components and the electric potential are set as the basic unknown variables and can be represented analytically through the transverse direction. The whole derivation is built upon the three dimensional key equations of elasticity for the piezoelectric materials and no assumptions on the plate kinematics have been taken. By virtue of the equilibrium equations, the constitutive relations and the introduced set of scaled boundary coordinates, three-dimensional governing partial differential equations are converted into the second order ordinary differential matrix equation. Furthermore, aided by the introduced internal nodal force, a first order ordinary differential equation is obtained with its general solution in the form of a matrix exponent. To further improve the accuracy of the matrix exponent in the SBFEM, the PIA is employed to make sure any desired accuracy of the mechanical and electric variables. By virtue of the kinetic energy technique, the global mass matrix of the composite plates constituted by piezoelectric laminae is constructed for the first time based on the SBFEM. Finally, comparisons with the exact solutions and available results are made to confirm the accuracy and effectiveness of the developed methodology. What's more, the effect of boundary conditions, thickness-to-length ratios and stacking sequences of laminae on the distributions of natural frequencies, mechanical and electric fields in laminated piezoelectric composite plates is evaluated.

• Journal of Astronomy and Space Sciences
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• v.19 no.4
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• pp.243-254
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• 2002

Various uncertainties involved in ionospheric conductivity estimation utilizing the electron density profile obtained from the Sondrestrom incoherent scatter radar are examined. First, we compare the conductivity which is based on raw electron density and the one based on corrected electron density that takes into account the effects of the difference between the electron and ion temperatures and the Debye length. The corrected electron density yields higher Pedersen and Hall conductivities than the raw electron density does. Second, the dependence of collision frequency model on the conductivity estimation is examined. Below 110 km conductivity does not depend significantly on collision frequency models. Above 110 km, however, the collision models affect the conductivity estimation. Third, the influence of the electron and ion temperatures on the conductivity estimation is examined. Electron and ion temperatures carrying an error of about 10% do not seem to affect significantly the conductivity estimation. Fourth, also examined is the effect of the choice of the altitude range of integration in calculating the height-integrated conductivity, conductance. It has been demonstrated that the lower and upper boundaries of the integration are quite sensitive to the estimation of the Hall and Pedersen conductances, respectively.

• Analytical Science and Technology
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• v.19 no.5
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• pp.400-406
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• 2006

Hydrogen analysis by elastic recoil detection has been performed utilizing polyimide film as a reference sample of known hydrogen content assuming the soundness of ion beam current integration. However beam current integration at higher incidence angle is not reliable. Scattering yield per unit fluence by current integration which is normalized per unit path length decreases as the sample tilt angle is getting higher. Moreover because beam current integration at high tilt angle is incomplete, hydrogen evaluation is very risky by direct comparison of sequentially collected recoil spectra between reference and target sample. In this study, primary ion beam dose is determined by backscattering spectrum that is collected simultaneously with recoil spectrum instead of ion beam current integration in order to reduce uncertainty arising in the process of current integration and to enhance the reliability of quantitative analysis. Three test samples are selected $-7.6{\mu}m$ polyimide film, hydrogen implanted silicondioxide and Au deposited carbon wafer- and analyzed by two methods and compared.

• Journal of the Institute of Electronics Engineers of Korea TC
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• v.43 no.4 s.346
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• pp.44-51
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• 2006

In this paper, the resonance characteristics of zigzag wire dipole antennas are first analyzed by the method of moment(MOM) for shortening the space occupation length of straight wire dipole antenna Considering the shortening effect the integrated zigzag dipole antennas with the simplified microstrip feed are designed. Since the integration gives rise to discontinuities due to antenna line width with abrupt bend angles, the compensation by the chamfer is applied. Futhermore the integrated parasitic zigzag lines are properly attached to both sides of substrate for compensation of the effect of the dielectric substrate, hence improving the resonance characteristic. The design results at UHF and ISM band are verified with experiments.

• KSCE Journal of Civil and Environmental Engineering Research
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• v.4 no.1
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• pp.69-77
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• 1984

In this paper, the governing differential equations for the free vibration of uniform parabolic arches are derived on the basis of equilibrium equations of a small element of arch rib and the D'Alembert principle. A trial eigen value method is used for determining the natural frequencies and mode shapes. And the Runge-Kutta fourth order integration technique is also used in this method to perform the integration of the differential equations. A detailed study is made of the first mode for the symmetrical and anti-symmetrical vibrations of hinged arches with the Span length equal to 10 m. The effects of the rise of arch, the radius of gyration and the rotary inertia on free vibrations are presented in detail in curves and table.

• Journal of the Microelectronics and Packaging Society
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• v.23 no.4
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• pp.69-77
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• 2016

We propose nano-scale Cu direct bonding technology using ultra-high density Cu nano-pillar (CNP) with for high stacking yield exascale 2.5D/3D integration. We clarified the joining mechanism of nano-scale Cu direct bonding using CNP. Nano-scale Cu pillar easily bond with Cu electrode by re-crystallization of CNP due to the solid phase diffusion and by morphology change of CNP to minimize interfacial energy at relatively lower temperature and pressure compared to conventional micro-scale Cu direct bonding. We confirmed for the first time that 4.3 million electrodes per die are successfully connected in series with the joining yield of 100%. The joining resistance of CNP bundle with $80{\mu}m$ height is around 30 m for each pair of $10{\mu}m$ dia. electrode. Capacitance value of CNP bundle with $3{\mu}m$ length and $80{\mu}m$ height is around 0.6fF. Eye-diagram pattern shows no degradation even at 10Gbps data rate after the lamination of anisotropic conductive film.

• KSII Transactions on Internet and Information Systems (TIIS)
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• v.11 no.7
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• pp.3393-3412
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• 2017

As a main challenge in network virtualization, virtual network embedding problem is increasingly important and heuristic algorithms are of great interest. Aiming at the problems of poor correlation in node embedding and link embedding, long distance between adjacent virtual nodes and imbalance resource consumption of network components during embedding, we herein propose a two-stage virtual network embedding algorithm NA-PVNM. In node embedding stage, resource requirement and breadth first search algorithm are introduced to sort virtual nodes, and a node fitness function is developed to find the best substrate node. In link embedding stage, a path fitness function is developed to find the best path in which available bandwidth, CPU and path length are considered. Simulation results showed that the proposed algorithm could shorten link embedding distance, increase the acceptance ratio and revenue to cost ratio compared to previously reported algorithms. We also analyzed the impact of position constraint and substrate network attribute on algorithm performance, as well as the utilization of the substrate network resources during embedding via simulation. The results showed that, under the constraint of substrate resource distribution and virtual network requests, the critical factor of improving success ratio is to reduce resource consumption during embedding.

• Korean Journal of Computational Design and Engineering
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• v.20 no.4
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• pp.431-442
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• 2015

Currently, a BIM-based quantity takeoff (QTO) system is mainly focused on architectural projects. To perform this, diverse quantity takeoff methods such as an object-based automatic quantity takeoff, manual quantity and base functions of calculation have widely been utilizing. However, since BIM library for road projects includes structural elements associated with alignment, it is necessary to establish cost estimation system interlocked with historical cost using 3D library by each unit length. Accordingly, the aim of this study is to develop cost estimation model with using a historical cost approach so that it can be utilized in construction planning based on the BIM library for road projects. For this, based on the BIM library for road, the standardized quantity is estimated, and a process for calculating historical cost and a verification model with a 5D simulation was developed by mapping a WBS code with each BIM library object. This can be applied during the approximate cost estimation process in a project planning and an initial design phase for road projects. Besides, it is expected that these results will be utilized in constructing an optimal historical cost estimation process for project libraries.