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)

알루미늄 합금의 이종 마찰교반접합

송상우,김남규,강정윤,Song, Sang-Woo,Kim, Nam-Kyu,Kang, Chung-Yun 대한용접접합학회 2009 대한용접·접합학회지 Vol.27 No.5

마그네슘 및 알루미늄 합금의 마찰교반접합시 액화균열의 발생

송상우,김남규,강정윤,Song, Sang-Woo,Kim, Nam-Kyu,Kang, Chung-Yun 대한용접접합학회 2010 대한용접·접합학회지 Vol.28 No.5

외국계 투자펀드에 대한 조세조약의 적용과 과세문제

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.

대학축구지도자의 삶의 과정에 관한 근거이론적 접근

송상우(Song, Sang-Woo),정성국(Jung, Sung-Gook),박창범(Park, Chang-Beom) 한국체육과학회 2013 한국체육과학회지 Vol.22 No.4

This study uses the grounded theory method based on Strauss and Corbin(1998). All interviews were conducted with 6 collegiate soccer coach who are instructing their team. The study process was explained and the informants signed the consent form before the interviews. Informant’s training log and researcher’s memos were made to describe informants’ behavior during the interviews and participant observations. Date were collected with in-depth interviews and participant observations and coach’s training log until they were saturated. The content analysis was used to analysis were developed into categories representative of the coach’s life-experience process. With the data analysis, 138 concepts, 45 subcategories, and 21 categories were generated. In axial coding, a paradigm model was proposes as follows: The causal condition was ‘trying to be a collegiate coach’ and the central phenomenon was ‘hardly living for team and family’. The contextual conditions that having influence upon this phenomenon were ‘responsibility as a coach’, ‘responsibility as a family member’, and ‘individual greed’. The interventing conditions that promoting or suppressing the strategy of action/interaction in this phenomenon were ‘understanding lack of social cognition and support’, ‘understanding social reality’, ‘recognition of individual responsibility’, ‘expectation of social resolution’, and ‘application of social network’s support’. The action/interaction strategies were ‘active responses’, ‘adjustment of given condition’, ‘acknowledgement’, ‘thinking as opportunity’, ‘relationship enrichment’, ‘don’t give up and waiting’, and ‘regarding as a vocation’. The consequences were ‘satisfaction of present life’, ‘hoping better treatments’, and ‘remaining my portion’.

실질과세원칙과 국제조세조정에 관한 법률 제2의 제1항

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.

대학축구지도자의 변혁적·거래적 리더십이 조직유효성에 미치는 영향

송상우(Song, Sang-Woo),신승엽(Shin, Seung-Yeop),박창범(Park, Chang-Beom) 한국체육과학회 2011 한국체육과학회지 Vol.20 No.5

The purpose of this study is to examine the effect of leadership types such as transformational leadership and transactional leadership and transactional leadership of university soccer coaches on job satisfaction, organizational commitment, and intention to leave of soccer players. To achieve these goals, hypothesis and test was accompanied. Based on the 247questionnaires from university soccer team players, analysis of variance and multiple regression analysis were applied. According to analysis of variance, perceived leadership level appeared partly to be different and according to platers" grades and positions in soccer team. benly charisma and contingent reward showed different according to their grades, and inspirational leadership appeared to be different according to their positions. According to multiple regression analysis, All leadership styles except of exceptional leadership appeared to have positive effects on job satisfaction under the significance level of 0.01. And all leadership styles except of charisma appeared to have positive effects on organizational commitment under the significance level of 0.01. Charisma, intellectual stimulation and contingent reward appeared to be negative effects on intention to leave, but individual consideration, inspirational leadership and exceptional leadership not to be effective on intention to leave under the significance level of 0.01.

경주지역 고분 출토 단각고배에 관한 연구

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).

서로 다른 분산 비디오 저장 서버를 위한 데이터 할당과 부하 조정

송상우(Sang-Woo Song),정병수(Byung-Soo Jeong) 한국정보과학회 2000 한국정보과학회 학술발표논문집 Vol.27 No.2Ⅰ

비디오 저장 서버를 설계하는데 가장 주안을 두어야 할 점은 서버의 이용률을 증가시키고 그에 따른 비용을 최소화 해야 한다는 점이다. 이를 위한 서버로 분산 비디오 저장 서버가 주로 이용되고 있고, 그 목적으로는 균등한 비디오 할당과 부하 조정(load balancing)이 제안되어 왔다. 이에 대한 방안의 하나로 디스크 기반의 비디오 저장 서버 클러스터에서 부하 시프팅(load shifting)이 그 목적을 이루기 위한 한가지 방법으로 연구되었다. 이것은 동일한 용량의 서버로 구성된 비디오 서버 클러스터에서 비디오를 다른 서버에 복사해 놓고, 사용되고 있는 비디오 요구시 그 비디오에 대한 요구를 다른 서버의 복사본으로 이동시킴으로써 서버들에 대해 균등한 비디오 할당을 하고 서버나 비디오의 추가와 같은 동적인 변화에 대해 데이터 할당 및 부하 조정을 감안하여 제안된 것이다. 이 논문에서는 기존의 동일한 서버만을 사용한 것과는 달리 용량이 서로 다른 서버나 비디오를 추가할 경우에 요구되는 최적의 비디오 데이터 할당과 부하 조정에 관한 전략에 관하여 설명한다.

스포츠 지도자의 리더십 유형이 집단응집력과 선수만족도에 미치는 영향에 관한 연구

송상우(Song, Sang-Woo) 한국체육과학회 2014 한국체육과학회지 Vol.23 No.5

The purpose of this study is to define how the leadership types of coaches in soccer teams affect the group cohesiveness and the satisfaction of players. Concretely speaking, the study set the types of leadership, displayed through interactions between the coaches and the players of the soccer teams, as an independent variable as it regarded the group cohesiveness as an intervening variable. The satisfaction of the players was determined as a dependent variable. With all the variables clearly established, the study was conducted to understand which leadership type is most effective and how to deal with such roles efficiently. The research methods are described in detail as follows. First, the study figured out roles of coaches in sports groups and came up with types of those coaches’ leadership. Second, the study investigated how those five leadership types which have been sorted out through an analysis affect the group cohesiveness. In order to achieve the research goal, the study conducted a survey targeting players of soccer teams in universities, and the data was collected for about two months from 11 to 12 in 2013. A total of 246 samples of the respondents were collected, and the study applied ver. spss21 in carrying out the multiple regression analysis. The findings from the analysis, first, reported that of all the sub-factors of the leadership types, those variables except for the ‘positive compensatory behavior’ were observed to have a significant influence on the socially-oriented cohesiveness and the task-oriented cohesiveness which are the sub-variables of the group cohesiveness. Second, in terms of the relation of the group cohesiveness with the satisfaction of the players, only the socially-oriented cohesiveness appeared to have a significant effect. Based on such research results, the study, now, approaches a significant conclusion after a more in-depth discussion over the efficient roles of the coaches.