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三星根据一项专利许可协议被判逃税，并被要求缴纳134万美元的公司税。_我的网站

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    American teacher Ronald Sakolsky reunites with desert fighter Yin Yuzhen at an airport in Ordos, North China's Inner Mongolia Autonomous Region on August 23, 2026. Photo: Xinhua
    
A long-awaited reunion that captured wide public attention unfolded on Sunday evening when American teacher Ronald Sakolsky and Yin Yuzhen, a model worker renowned for planting trees and combating desertification, reunited and embraced tearfully with overwhelming emotion at an airport in Ordos, North China's Inner Mongolia Autonomous Region, after 27 years of separation across the ocean.
The reunion began with a single act of generosity in 1999. When Sakolsky arrived in China as a participant in a China-US education exchange program, he was moved by Yin and her husband's tireless efforts to curb desertification in the Mu Us Desert in Inner Mongolia. He raised $5,000 to fund their local tree-planting initiative. The young saplings they bought with the donation have since matured into more than 50,000 full-grown trees, transforming the once desolate, sandy wasteland into a thriving green landscape.
This hug, transcending time and distance, marked not only friendship between the two countries, but also showcased the sincerity of Chinese people and a green miracle made possible through continuous joint efforts. 
         Seeds of China-US friendship sown long ago, now stand as towering woods. Illustration: Liu Rui/GT     Hug across 27 years 
At 2:48 am on early Sunday morning, Ronald Sakolsky arrived at Beijing Capital International Airport after over 10 hours of flight. As he stepped into the arrivals hall, he greeted the waiting reporters with earnest Putonghua "Wo hui lai le," meaning "I'm back."
"When I saw the lights in Beijing as we were landing is when I realized that I am back in my second home." 
Asked what he is most looking forward to about this journey, Sakolsky told the Global Times that "I want to see Ms Yin, see the forests, see the students I have not seen for almost 30 years, my colleagues. I want to see the Chinese people." 
He then flew to Ordos for the meeting with his desert reclamation partner. 
Yin waited at the arrival gate at the airport in Ordos very early, murmuring English sentence she particularly learned for this occasion - "Welcome to China, my brother." Her eyes were fixed on the escalator and she wiped away her tears multiple times during the wait, the Global Times reporter observed. 
Sakolsky said in earlier interview with the Global Times that he was looking forward to this reunion and could not hold his tears back when he thought of the moment. He was about to give Yin a hug when they meet. 
When Sakolsky finally appeared in front of Yin, their eyes welled up. Stepping off the elevator, Sakolsky could barely contain his excitement, muttering "Oh my God, oh my God." They hurried toward each other and locked in a tight embrace at last - the long-awaited hug 27 years in the making. 
"This is a dream come true, from a lady who is the hero of the story, not me," Sakolsky told the Global Times at the airport, barely holding his emotion. "She made a promise 27 years ago, and she kept her promise." 
Talking about his donation almost three decades ago, Sakolsky said the purpose was to help her, "because she was beautifying the motherland." 
Now, in response to an invitation to return to China for a trip to see the green planting from his donation and to returning to the city of Luoyang, Central China's Henan Province, where he taught in the exchange program for several years, Sakolsky noted that "China had done so much for me that I wanted to say thank you to China."
A return of kindness 
For this reunion after 27 years, Yin had carefully prepared. Steamed buns, meaning "upward," fresh vegetables and fruits picked in the land transformed from desert.
Yin, never familiar with any foreign language, learned some English phrases, including "welcome to China" she practiced, "my brother" to greet Sakolsky, and "more, more" to persuade the American friend to eat more. 
On Sunday, Yin did her hair and wore a red scarf alongside an outfit with a green shade, which she picked particularly for the reunion, as "green is the color of the Earth," as she told the Global Times.
Yin is not the only old friend that was looking forward to the reunion. 
While Sakolsky was still on his over-10-hour flight from the US to Beijing, Bai Fan was also on the way - driving over 850 kilometers from Luoyang to Inner Mongolia. The journey would take a day and a half. 
Bai was the vice principal of Luoyang Foreign Language School, overseeing international affairs. Sakolsky was an exchange teacher there through a China-US program, and was Bai's "neighbor right across the hall."
Why drive such a distance? Bai had prepared special cultural gifts - peony porcelain and Hanguan Kiln purple clay tea ware, distinctive local handicrafts that proved too bulky and fragile for air travel or high-speed rail. 
Bai recalled Sakolsky's continuous interest in Chinese culture, and sending a replica of Terracotta Warriors to the US at Sakolsky's request. "I hope he can take these Luoyang elements and Chinese symbols to the world," Bai told the Global Times in a phone interview on Sunday. 
Bai is also eager to see Sakolsky at a place that they had traveled together 27 years ago. When Sakolsky came to Luoyang for the exchange program, Bai was his designated liaison. Together, they traveled to the heart of the Mu Us Desert to deliver the $5,000 donation.
Bai still vividly remembers the desolate desert back then, where finger-thin saplings were watered ladle by ladle by Yin. At that time, Sakolsky had constant concerns about whether the tiny saplings could survive in the wasteland, which makes today's sprawling 50,000-tree forest even more miraculous.
The changed and unchanged 
Things have changed over the past 27 years. While waiting for Sakolsky, Yin jokingly said he got less hair, and she would not be able to recognize him if running up to him on street. 
The passage of time has brought far more than personal aging, according to Bai, another witness to the decades-long changes. "Everyone is growing older. Our families have expanded with more children, local communities have grown in population, and the surrounding environment is constantly evolving, just as our cities are undergoing profound transformations." 
On a night tour in Ordos on Sunday, Sakolsky, watching a fountain light show, said that "it is a 21st century city, but it looks like a 22nd century city. In the 2000s, Chinese government made a promise to Chinese people to beatify this country, and they succeeded." 
For Sakolsky, probably the most profound transformation lies in the depth of his human connection forged. 
"27 years ago, we were just friends and acquaintances. We are brother and sister now. So much has happened since then, but the important thing is many people have seen the story and now they can also help to make China beautiful," he told the reporters. 
Through joint efforts of people like Yin, the Mu Us Desert has turned from wasteland into a green oasis. China has contributed about 25 percent of the world's newly added green areas and taken the lead in achieving zero growth in land degradation, per official data. 
Meanwhile, there are things unchanged, including a vintage photo of the three standing in the desert that has decorated Bai's office through all these years - a permanent reminder of their original aspiration. 
This reunion will witness them retake the classic photo and plant new saplings together, expanding their green mission. 
。北京时间1月9日，韩国最高法院周三裁定，三星电子与一家爱尔兰导管公司达成专利许可协议，以利用韩国爱尔兰税收协议中的特别豁免条款逃税并支付15亿韩元（134万美元）的公司税。导管公司的成立通常是为了逃避或减少税收，转移或积累利润。韩国最高法院星期三对三星做出裁决，结束了长达五年的诉讼。

二 | 三星在2013年以原告的身份向韩国最高法院提出上诉，质疑韩国税务机关让三星承担706亿韩元的公司税的决定。

三 | 然而，韩国最高法院仅部分支持上诉法院的判决，即三星只应承担15亿韩元的企业税。

四 | 早些时候，上诉法院裁定三星应承担所有706亿韩元的公司税。韩国最高法院认为应该取消海外专利税。

五 | 2010年，三星与美国全球知识产权管理公司IntelligentVentures签订了专利许可合同，支付后者3.7亿美元。

六 | 高志敏表示，其爱尔兰子公司四一是协议的一方，因此该协议应享受韩国爱尔兰税务协议中的公司免税条款。根据韩美税制，被许可方应支付15%的许可费作为公司税。然而，韩国税务官员表示，IvIl只是一家避税公司，因此他们向三星签发了一份706亿韩元的税单。

七 | 尽管下级法院接受了三星的反驳，但上诉法院推翻了判决，并裁定三星对所有税收负有责任。

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Published on:14:27:38