The article focuses on a long-standing conflict between the Korean tax authorities and the courts in respect of “royalties” as prescribed by the tax treaty between the Republic of Korea and the United States. In this specific but significant set of circumstances, a Korean resident manufactures certain goods with a view to selling them in the US market, and in the course of its manufacturing, infringes upon a US Patent. Disputes have arisen as to the source and nature of the arising cross-border payments.