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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)
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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)
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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).
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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.
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宋尙雨(Sang Woo Song),鄭光鎭(Kwang Jin Jung) 한국세법학회 2007 조세법연구 Vol.13 No.1
투자펀드가 조세조약의 적용을 받기 위해서는 조세조약의 양 체약국 또는 일방체약국의 거주자인 인이어야 한다. 그런데 투자펀드의 경우 직접투자의 경우와 비교하여 조세중립성을 확보해 주기 위하여 각국에서는 과세상 특별한 취급(pass-through)을 하는바, 이러한 과세상 특별 취급 때문에 당해 투자펀드가 조세조약상 거주자에 해당하는지 여부에 관하여 의문이 있을 수 있다. 이와 관련하여 조세조약상 수익적 소유자 개념 및 「국제조세조정에 관한 법률」상 국내원천소득이 사실상 귀속되는 자의 개념이 문제된다. 외국인이 투자펀드를 이용하여 얻는 수입의 종류는 주로 이자?배당?양도소득으로 구성될 것이므로 국내원천소득으로 과세가 문제되는 소득의 종류도 주로 이와 같다. 우선 외국인투자펀드가 귀속되는 소득의 종류가 전환한 경우 실질과세원칙의 적용 여부가 다투어진다. 다음 최근 외국인투자펀드에 대한 과세문제로서 다투어지는 쟁점은 간주고정사업장의 인정문제이다. 간주고정사업장 쟁점은 외국투자펀드가 국내 자회사를 두고 외국인 투자펀드의 주요한 사업활동을 대리하는 경우 국내 자회사를 종속대리인으로 보고 고정사업장의 존재를 인정할 수 있는가의 문제이다. 또한 종속대리인이 외국인투자펀드의 고정사업장에 해당된다고 하더라도, 고정사업장이 부담하는 투자에 따른 위험과 역할을 기준으로 고정사업장에 귀속되는 과세소득을 어떻게 산출할 것인지에 관한 문제도 실제에 있어서 해결이 쉽지 않다. 투자펀드에 국내원천소득을 지급하는 자의 원천징수의무와 관련하여 실무상 그 확인의 어려움이 있다. 일반적으로 투자펀드에 대한 소득지급자의 원천징수의무에 관한 쟁점은 원천징수의무자와 원천납세의무자의 구제절차의 측면에서도 복잡한 쟁점을 안고 있다. 이를 해결하기 위하여 비과세 및 면제 확인절차를 개선할 필요성이 요청된다. The income of a foreign investment fund would be consisting of interest, dividend, or capital gain. Such income would be subject to Korean withholding tax, if they are sourced in Korea and they are not attributable to a permanent establishment (“PE”) in Korea. There have been discussions to tax on the income sourced in Korea of the foreign fund based on the deemed PE logic. Although a foreign fund has not physically presented in Korea, it could be viewed to have a PE if a subsidiary performed key business activities, without which the foreign fund unable to do business, in Korea on behalf of the foreign fund. In practical point of view, however, it would be difficult to determine whether the subsidiary performed key business activities or not. It also would be difficult to measure attributable income to the deemed PE based on the functions performed and risks assumed. A foreign fund should be a person who is a resident of one or both contracting states of tax treaty to have benefits from tax treaty provision. The term “resident of a contracting state” means any person who, under the laws of that state, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature. Many domestic regimes provide special tax treatments to investment funds to keep neutrality between investors using investment fund and those without using it. For such special tax treatments of a foreign fund, it is questionable for whether the fund is liable to tax for tax treaty access purpose. With such regard, it is practically difficult for a withholding agent to identify a beneficial owner under a tax treaty or a real owner of the income under the Law for Coordination of International Tax Affairs (the “LCITA”). The appeal or litigation procedure for the dispute of such withholding tax is not clear either. To resolve such uncertainty, it is recommendable to improve the process of the application and confirmation of tax exemption.
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