Korea-U.S. MOU on Tax Treaty Refers to Korean Concern over Simultaneous Trade and Tax Enforcement

On March 3, 1994, the Treasury Department confirmed that it and the Republic of Korea had reached agreement on several tax treaty issues, including a clarification that payments for software ordinarily should be regarded as business profits and therefore should be exempt from withholding taxes at the source. A memorandum of understanding (MOU) on tax issues was reached between the two governments in December 1993 after U.S. companies located in Korea made several complaints that they were receiving an unfair interpretation of the bilateral income tax treaty?[more]