As you probably know, it all depends on whether the facts would sustain a finding that LS had a “permanent establishment” in Korea (in respect of whatever subsidiary Belgian entity directly or indirectly actually owned Star Tower)that would result in such entity’s disqualification for the benefits available under Korea/Belgium tax treaty to an investor that has no substantive contacts with Korea other than a passive stock holding.

I know nothing when it comes to economics beyond reading English and you guys talk your own language…

So, if LS was a substantive corporation inside Korea, even if the Star Tower was owned officially by a Belgian-based company (that is part of LS), the sale of the tower would be considered a LS-Korea transaction and thus subject to Korea’s taxation.

At which point, I guess, somebody would have to sue the Belgian government for a refund on the chunk it took, right?

Since it seems loopholes are part of the life-blood of international conglomerates and others - like shipping companies…..I can’t make heads or tails of anything…..

But it sounds like Korea decided LS was ripe for the sucking….

But, I can read English.

Can someone clarify this for me:

The US fund had filed the complaint with the tribunal in 2006, saying its Belgium-based Star Holdings unit sold the building and thus should be exempt from taxes under a South Korea-Belgium treaty on avoiding double taxation.

http://www.forbes.com/markets/.....85429.html

Since it was a “double taxation” treaty, I am taking it the Lone Star affiliate was taxed in Belgium for the sale of the building and that money went into the Belgium coffers.

So, now, with yesterday’s ruling by the Korea panel, Korea’s law has upheld the idea that —

Since Lone Star is nothing but a big fund (read - American money machine raping and pillaging the world - especially South Korea), it cannot stand behind the Belgian-based firm that is a part of it to avoid - due taxation inside Korea.

So, basically, Korea is getting its cut of the sale by milking an easy target - a (Texas-based even!!) money mammoth…

I wonder what foreign holdings the major Korean chaebol have?

Sorry, but this is my one-man Internet crusade, to end the misuse of these words.

Perhaps even more chilling to Korea is that these firms, now stuck in Korea for the foreseeable future, will actual start to run the banks rather than recapitalizing or cutting their losses, and bailing out. This would defiantly mean more western management, and lot of more of the frictions associated with foreign banks (like cutting off credit to failing Korean companies or labor rankling layoffs). They will also start anew with pesky questions about offering new products and lowering the banking barriers between Korea and the world.

this is not the case. lonestar called it off as it was getting dragged beyond their sale date. in fact, the sales price is now in flux-could be more, could be less. i believe that the odds of it being more are greater than it being less. it would be in the investigation team’s interest to think deeply about who they’re playin’ ball with.

I always smile when I hear Woori’s campaign. I am remebered their school girl giddiness when the head of HSBC came by for a meeting when the hubbub of HSBC buying someone was at a fever pitch.

Origami> I make no claim of the guilt of Lone Star as of yet. I have yet to really look into the substance of it all. The Procecuters office may very well have a case from all I can tell at the moment. The shoe does fit, then again there are probaly stilleto heels that fit the Dram Man, but wearing them is not necessarly right choice. Same could be said about Chae’s situation.

(Speaking of looking foolish, Chae should have kept his mouth shut. Grayken made a statement in public and any first year law student could tell you that is technicaly slander not libel.)

For the record I have no real stake in this, save my KEB accounts and secured credit card.

Dram_man why don’t you tell us your stake in all this?