TITLE	Supreme Court Decision 2018Du36592 Decided February 10, 2022 ¡¼Lawsuit Claiming for Revocation of Disposition Refusing to Refund Withheld Corporate Tax¡½ [full Text]
Summary
¡¼Main Issues and Holdings¡½ [1] Where a United States corporation merely registered a patent right in a foreign country but did not register it in the Republic of Korea, whether the income that the United States corporation is paid in relation thereto can be deemed domestic source income (negative) [2] Where a domestic corporation used nonpublic information about inventions, technologies, etc. of intangible assets subject to the royalty payment under a contract concluded with a United States corporation, a patentee, in the Republic of Korea and paid the price therefor to the United States corporation, whether the royalty income of the United States corporation related thereto can be deemed domestic source income (affirmative)

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