Research Outcome:The title of thisresearch is Transfer Pricing International Taxation Law.  This study specifically focused on the Oiland Gas industry in Japan and Korea.  This study was presented at the Comparative International Governmental Accounting Research Conference in 2023. Also, a part of the research content was presented in a session at Yonsei University.  The outcome of this research is published in the 2024 edition of Waseda Global Forum. This studyintroduces carbon taxation in response to climate change, and prospectiveimpacts on the oil and gas industry focusing on transfer pricing strategies inJapan and Korea. Both Korea and Japan have implemented climate objectives toachieve a zero-carbon society. Both countries have revised the legislation toreduce fossil fuel subsidies. Japan has launched on the combined carbon taxscheme, and Korea is at an ongoing discussion stage whether to include carbonpricing mechanism into the existing exergy taxation.This studyfocused on two research questions: （1） How can the oil and gas industry develop transfer pricingstrategies in the carbon taxation jurisdiction different and the EmissionTrading Scheme? （2） How the oil and gas industry creates a sustainable supplychain as a proactive measure for transfer pricing risks under climate changeadaptation policies. This article explores how to achieve sustainable transferpricing strategies based on resilient R&D.The Oil and Gascompanies are already subject to a variety of taxes and levies. OG companieshave heavy tax payments to make under license rentals, royalties computed basedon production volumes, corporate income taxes, and taxes on the repatriation ofprofits. And, there are also reporting obligations to the Internal RevenueServices if any OG entities are doing business with the U.S. relatedparties.  Another challenging factor forthe OG is that the industry involves both tangibles and intangibles in the supplyand value chain. In this context, three hypotheticals are presented for samplesimulations.The impact ofcarbon tax on the OG industry will be more significant since the industryrelies on MNEs or joint venture projects that involve multiple jurisdictions.The OG industry will require corporations to adopt “resilient” transfer pricingstrategies. New transactions will likely evolve as the Carbon Border AdjustmentMechanism will be enforced where non-EU member nations will be affected. Theprice of risk or the market risk premium in the OG industries in Japan andKorea can be measured and predicted by the use of joint research activities.Japan and Korea responding to the carbon tax and energy transition throughtransfer pricing strategies, particularly in the OG industry can create a modelfor business entities in the time of climate change. Also, the active use ofadvanced agreements between or among different tax administrations with theentities at various stages in the OG industry will create a constructivetransfer pricing compliance scheme.

Cyberspacecreated a sphere where anyone can express his or her opinion about any theme. Onlinenewspaper articles in Japanese and in Korean created a distinctive local mediacoverage shaping the general public’s perception of Japan-Korea relationship. Thisresearch focused on how events or themes in online newspaper articles inJapanese and in Korean are differently interpreted. In this study, Japan-Koreaindicates Japan and the Republic of Korea or South Korea. The primary data usedfor this research are online newspaper articles limited to 300 articles publishedin 2014 and 300 individual blogs via search engines using Korea-Japan as a keyword in Japanese and in Korean. The notion of alterity or “the Other” isadopted as a part of the critical theoretical departure.  For the data selection, the year 2014 wasparticularly chosen because it was years after two historical landmark legalcases were brought by the district courts in Korea against the Japanese firms.Two cases that reversed the prior rulings are the former Mitsubishi HeavyIndustries and Nippon Steel. The Mitsubishi case had lasted for 16 years since thebeginning of the initial suit. The rulings were significant since Supreme Courtin Republic of Korea based their decisions on the illegality of Japan’s Protectoratetreaty against Korea in 1905 and invalidity of statute of limitations on tortdamages. Although the Korean media covered these two rulings extensively, onlyfew articles appeared in the Japanese newspapers. The rulings can be an examplefor both Korea and Japan to be able to step into the shoes of "the Other."

The Shift in Burden of Proof in Transfer Pricing Litigations  This text is a part of the outcome of research performed under a Waseda Univeristy Grant for Special Research Project 2015K-297.  The outcome of the research has been partly presented at International Conference on Innovation in and Management in January 2016.This article focused on analysis of transfer pricing litigations in Japan in relation to the criteria of the burden of proof in arm’s length pricing methods. Transfer pricing cases are used as primary data and the study analyzed the process of how hypothetical or secret comparables affect the final court decisions.  Transferpricing cannot be “an exact science” within the Japanese litigation system becauseburden of proof is primarily on the tax authority. Since the burden of productionis based on the judge’s psychological conviction, the taxpayer’s comparablesfor the arm’s length price can be rejected. This article attempted to prove that an arm’s length price in transferpricing encompasses a mechanism that involves estimation or hypotheticalcomparables.

日本のコロニアリズムにおける女性教育史特定課題研究成果概要の報告リーマージ2013A-644519世紀後半の女子教育の発展の視点から各国における共通性は明確である。バージニアウルフのThree Guineas (1938)では，女性のための教育の場が全くなく，女性が外部者に留まる程処遇が良くなるという社会が描かれている。ウルフは女子のための初等教育と中等教育が受け入れられた時と場において著書を書いた。大学教育は議論が分かれたままであった。19世紀の英国における論争は初等教育の権利についてであり，特に19世紀においては両性の低い社会階層に教育が行われるべきかそうかについてであった。しかし，女子に対する読みの教育については論争の余地はなかった。対照的に，韓国の近代女子教育の発展において独特だと考えられるのは，儒教原理が歴史の状況と視野に影響を与えた範囲である。