A critical analysis of the taxation of financial assets and financial liabilities in terms of section 24JB of the South African Income Tax Act
- Authors: Snyman, S L
- Date: 2016
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: http://hdl.handle.net/10962/4178 , vital:20630
- Description: Section 24JB of the Income Tax Act No. 58 of 1962 was introduced with effect from 1 January 2014 in order to govern the taxation of financial instruments of a covered person as defined. Section 24JB represents a significant departure from the standard tax principles for financial instruments and will therefore directly affect the timing of the imposition of tax on gains and losses on these financial instruments, resulting in a significant adverse cash flow effect for the taxpayer. The main purpose of the research is to investigate the meaning of the wording in section 24JB through a critical analysis of the domestic tax legislation in the context of practical examples of specific financial assets and liabilities. The research includes an analysis of the scope of section 24JB by examining the definition of a “covered person” as well as the specific financial instruments to which the section applies, with reference to the International Financial Reporting Standards classifications and terms. The interaction of section 24JB with the rest of the Act is examined and whether this section overrides all the other provisions, specifically with reference to the taxation of dividends and the general and specific anti-avoidance provisions contained elsewhere in the Act. The study aims to highlight anomalies and possible unintended tax consequences arising from the current drafting of section 24JB using practical examples, highlighting the major areas of concern and issues of interpretation of section 24JB. Recommendations are made for amendments to the Act or the provision of guidance in the form of an Explanatory Memorandum or Interpretation Note to be issued by SARS.
- Full Text:
- Authors: Snyman, S L
- Date: 2016
- Language: English
- Type: Thesis , Masters , MCom
- Identifier: http://hdl.handle.net/10962/4178 , vital:20630
- Description: Section 24JB of the Income Tax Act No. 58 of 1962 was introduced with effect from 1 January 2014 in order to govern the taxation of financial instruments of a covered person as defined. Section 24JB represents a significant departure from the standard tax principles for financial instruments and will therefore directly affect the timing of the imposition of tax on gains and losses on these financial instruments, resulting in a significant adverse cash flow effect for the taxpayer. The main purpose of the research is to investigate the meaning of the wording in section 24JB through a critical analysis of the domestic tax legislation in the context of practical examples of specific financial assets and liabilities. The research includes an analysis of the scope of section 24JB by examining the definition of a “covered person” as well as the specific financial instruments to which the section applies, with reference to the International Financial Reporting Standards classifications and terms. The interaction of section 24JB with the rest of the Act is examined and whether this section overrides all the other provisions, specifically with reference to the taxation of dividends and the general and specific anti-avoidance provisions contained elsewhere in the Act. The study aims to highlight anomalies and possible unintended tax consequences arising from the current drafting of section 24JB using practical examples, highlighting the major areas of concern and issues of interpretation of section 24JB. Recommendations are made for amendments to the Act or the provision of guidance in the form of an Explanatory Memorandum or Interpretation Note to be issued by SARS.
- Full Text:
I have gone away many times
- Metileni, Moses Nzama Khaizen
- Authors: Metileni, Moses Nzama Khaizen
- Date: 2016
- Language: English
- Type: Thesis , Masters , MA
- Identifier: vital:6010 , http://hdl.handle.net/10962/d1021225
- Description: I search for beauty and for myself amidst the debris and ruin and violence, so my poems are mainly grounded narratives that combine the lyrical and the political, celebration and lament. They reconnect with nature, the now ravaged landscapes that gave me my first impulse to make songs, poetry, and art. My poems also draw on my Xitsonga culture – its folklore, proverbs, idioms, parables, and clan praise songs. Stylistically I am influenced by Mahmoud Darwish’s and Garcia Lorca’s musical structures, while Aimé Césaire has shown me how to write a long poem in both abstract and concrete registers, and Yehuda Amichai how to write with a questioning style, dislodging accepted dogma. Local influences are Mzi Mahola and James Magaisa, with their critique and celebration of culture. I pick up fragments elsewhere, as I go.
- Full Text:
- Authors: Metileni, Moses Nzama Khaizen
- Date: 2016
- Language: English
- Type: Thesis , Masters , MA
- Identifier: vital:6010 , http://hdl.handle.net/10962/d1021225
- Description: I search for beauty and for myself amidst the debris and ruin and violence, so my poems are mainly grounded narratives that combine the lyrical and the political, celebration and lament. They reconnect with nature, the now ravaged landscapes that gave me my first impulse to make songs, poetry, and art. My poems also draw on my Xitsonga culture – its folklore, proverbs, idioms, parables, and clan praise songs. Stylistically I am influenced by Mahmoud Darwish’s and Garcia Lorca’s musical structures, while Aimé Césaire has shown me how to write a long poem in both abstract and concrete registers, and Yehuda Amichai how to write with a questioning style, dislodging accepted dogma. Local influences are Mzi Mahola and James Magaisa, with their critique and celebration of culture. I pick up fragments elsewhere, as I go.
- Full Text:
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