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법인소득과 배당소득의 이중과세 조정에 관한 연구 : 기업의 채무구조와 관련하여
송상우 서울市立大學校 經商大學 稅務學科 1995 稅務學論集 Vol.8 No.-
법인소득과 배당소득의 이중과세 조정에 관한 연구(기업의 채무구조와 관련하여)
알루미늄 chip 의 용해시 산화피막 제거에 미치는 Flux 혼합물의 영향
송상우,김정호,김경민,김정식,윤의박 ( Sang Woo Song,Jeong Ho Kim,Kyoung Min Kim,Jung Sik Kim,Eui Pak Yoon ) 한국주조공학회 1998 한국주조공학회지 Vol.18 No.1
N/A Aluminum alloy forms rapidly a layer of oxide on surfaces exposed to an oxygen-containing atmosphere and absorbs hydrogen gas by reaction with water vapor. Oxidation accelerates as time and temperature increase. Also hydrogen content increase with time and temperature. In this experiment, A356.2 aluminum chip was used. The ability of oxidation protection of covering fluxes and oxide removal ability of flux additives were evaluated. Recovery and hydrogen content of Al melt was measured with various NaCl/KCl ratio. And recovery was measured with various flux additives such as chlorides and fluorides. The optimal ratio of NaCl/KCl for protection of oxidation was 5:5. Fluorides were more effective in removal of oxide than chlorides. (Received July 23, 1997)
송상우 ( Sang Woo Song ) 대구사학회 2010 대구사학 Vol.101 No.-
As representative of the latter style pottery in Silla, during the Three Kingdoms period, short mounted cups(短脚高杯, goblets) have been studied that were made in Gyeongju during the sixth century. This was when the tomb system changed from stone-surround wooden chamber tomb(積石木槨墳) into horizontal stone chamber tomb(橫穴式石室墳). Cups found in each tomb system were analyzed and compared. Also, near the lime the cups were created, Hwangryong-sa temple(皇龍寺) was constructed. It`s generally recognized that these short mounted cups as a remarkable relic of a certain period of time since they were widely found in the entire region of the Silla dynasty after the seventh century. In order to clarify the culture during the time of Silla, it`s prudent to examine the design of short mounted cups from Gyeongju, which was the capital of the Silla dynasty. Therefore, this paper focuses on the typological analysis of short mounted cups excavated from tombs in the Gyeongju region. The purpose of this paper is to understand the transition of short mounted cups and to place it in chronological order. First, short mounted cups excavated from other tombs with a stone mound were analyzed. Second, short mounted cups from horizontal stone chamber tombs were also analyzed. The two results were then compared against each other. While focusing on the from of the end of foot of the cups in established studies, a large opening called `Toochaig`(透窓) and a small opening named `Toogong`(透孔) were not definitively examined in the past, but are clearly defined in this paper. Moreover, it appears that the most effective ways to see the change in time order of short mounted cups during the Silla tomb style transition are the form of the end of foot of the cups and the combinations of the small and large openings in the foot of the cups. According to the existing theories, a short mounted cup only refers to very short footed mounted cups with a prominent cover-supporting rim(蓋收部). In this study, during sixth and seventh centuries mounted cups which have equal proportions as well as ones which have shorter foot part than cup part were also dealt with and named small size mounted cups(with cover-supporting rim) and small size mounted bowls(without cover-supporting rim). The judgement of classifying the type of cups was made according to the presence of cover-supporting rims or project lines. Each type of cups were then subclassified into three different patterns according to the features of the end of foot and the combinations with large openings or small openings. three different stages of short mounted cups were defined based on chronological order from the early sixth century to the late seventh century. Lastly, The coexistence and time order of these artifacts was confirmed through analyzing other relics and by seriation method. The features of each of these three stages were also examined. It was confirmed that short mounted cups were made during the time from extinctive period of stone-surround wooden chamber tombs until the period of prosperity marked by horizontal stone camber tomes and pottery with stamped ornamental designs(印花紋土器).
송상우(Song Sang Woo) 한국국제조세협회 2006 조세학술논집 Vol.22 No.2
After Korean economic crisis in 1997, many foreign companies invested to Korean companies. They repatriated their investment and related profits by selling their equity in Korean companies. According to Korean tax law, capital gains from dealing of shares are subject to Korean taxation at 25% of capital gains or 10% of the proceeds, whichever is lesser. Since many foreign companies used intermediary companies to invest Korea, there have been controversies for whether the treaty benefits under the tax treaty made between Korea and the residence country of intermediary company should be given or not. This article discussed the requirements of a resident to enjoy tax treaty benefits and inter-relation with the revised Article 2-2(1) of the Law for Coordination of International Tax Affairs (the LCITA). According to the revised Article of LCITA, the real recipient of income in economic sense can enjoy treaty benefits. I made three recommendations. (ⅰ) it would be required to give guidelines for who can be considered as real recipient of income by the Korean tax authority, (ⅱ) since the withholding agent can be exposed to pay withholding tax and related penalties even (s)he acted in good faith, there should be relevant considerations to withholding agents acted in good faith, and (ⅲ) revising pre-existing tax treaties could be useful to avoid uncertainty that was arising from the application of domestic anti-avoidance rule when the relevant tax treaty was silent for substance-over-form.
MRF기법을 이용한 하이브리드 차량용 교류발전기 냉각 팬 유동해석
송상우(Sangwoo Song),허남건(Nahmkeon Hur),권정기(Jungki Kwon) 대한기계학회 2015 대한기계학회 춘추학술대회 Vol.2015 No.11
In this research, the main purpose is to investigate the alternator cooling fan performance. The CFD simulation has been performed for various inlet/outlet angles and the flow fields is compared. The realizable k-ε turbulence model is used and for the rotating effect the MRF method is applied. The rotation speed is set up to 2000 rpm and the number of blades is set up to 11. As a result influence of inlet/outlet angles and air temperature on cooling fan performance is analyzed.