1. 질의내용 요약
We have a Korean income tax problem and would appreciate any assistance your office can extend in order that we may receive a refund.
The background information is as follows and copies of all documents are enclosed:
a) A Development and Licensing Agreement signed April 26, 1995 with Samsung Electronics Ltd. to design and develop a Multi-function device for engineering work performed in the United States for $650,000.
b) A memorandum dated September 5, 1995 to Mr. Ken Kim of Samsung Electronics Ltd. from their law firm, Venture Law Group. (possible tax exposure $15,000)
c) An opinion from Wolf & Co. (Ms. Carol Tully) to XLI. (no tax exposure)
d) Copies of the Certifications of taxes paid to the Korean Tax Authority amounting to $104,812.50.
We are a small business with over 8 million in loss carry forward, applying the $104,812.50 to any U.S. tax liability is many years in the future.
If you could outline the necessary procedures so the we may receive a refund, we would be very grateful.
Thank you in advance.