South Africa has adopted a general anti-avoidance rule (GAAR) as one of the methods to combat the innovative tax avoidance schemes into which taxpayers may enter. Nevertheless, since its introduction it has undergone numerous amendments due to weaknesses highlighted by its failures in court. Yet, since its most recent amendment in 2006, the efficacy of the South African GAAR has not been established as it has not been tested in the courts. This study addresses this concern by employing a ‗structured pre-emptive analysis‘ to identify the weaknesses of the South African GAAR when compared to its New Zealand counterpart. This approach is essentially qualitative and combines the typical doctrinal or black letter law approach used in law with that of reform-oriented approaches. Firstly, the South African and New Zealand GAARs were analysed and compared using a doctrinal approach to gain an understanding of the interpretation and application of the two GAARs. This allowed for the identification of weaknesses in the South African GAAR, whilst also making suggestions for its improvement. Thereafter, the South African GAAR was applied to the facts of a case from New Zealand by making use of a reform-oriented methodological approach. In applying the South African GAAR to the facts of the case, a framework of the South African GAAR was used to enhance the reliability of the findings by reducing subjectivity and improving replicability. The findings from the doctrinal and reform-oriented approaches revealed the weaknesses in the current South African GAAR when compared to its New Zealand counterpart. These weaknesses may be addressed in three ways. Firstly, guidance should be provided in order to address uncertainties in the interpretation and application of the South African GAAR so as to prevent inconsistencies that may limit its efficacy. Secondly, the purpose requirement and tainted elements could be consolidated into one requirement, where the presence of one of the tainted elements informs the objective purpose of the arrangement. Thirdly, the purpose requirement should be amended so that it need not be the sole or main purpose, but rather should be one of the purposes, provided it was not merely incidental. It is acknowledged that while the South African and New Zealand GAARs are directed to achieve the same end, the proposals for amendment would arguably go some way towards improving the efficacy of the South African GAAR. / Mini Dissertation (MCom (Taxation))--University of Pretoria, 2020. / Taxation / MCom (Taxation) / Unrestricted

A look into song identity and the building blocks of music through a process of analysing five different punk songs and then repackaging them into a modern pop production. After completing these new versions, I compared them to their original recordings and discovered that there are more similarities between the two genres than one might initially think, and that each song’s identity was preserved on slightly different levels and in different forms. I discuss my analyses and process in terms of both music theory and non-musical descriptions, leading to generally positive results. Each song was recognizable, but I discovered that some identities were stronger than others because of factors such as original arrangement, era of release or differences in experience from person to person.

Cell-substrate interactions are important to study for development of accurate in vitro research platforms.  Recently it has been demonstrated that physical microenvironment of cells directly affects cellular motility and cytoskeletal arrangement.  Specifically, previous studies have explored the role of material stiffness (Young's modulus: N/m2) on cell behavior including attachment, spreading, migration, cytoskeleton arrangement (stress fiber and focal adhesion distribution) and differentiation. In this study using our recently described non-electrospinning fiber manufacturing platform, customized scaffolds of suspended nanofibers are developed to study single cell behavior in a tunable structural stiffness (N/m) environment.  Suspended fibers of three different diameters (400, 700 and 1200 nm) are deposited in aligned configurations in two lengths of 1 and 2 mm using the previously described STEP (Spinneret based Tunable Engineered Parameters) platform.  These fibers present a gradient of structural stiffness to the cells at constant material stiffness.   Single cells attached to fibers are constrained to move along the fiber axis and with increase in structural stiffness are observed to spread to longer lengths, put out longer focal adhesions, have elongated nucleus with decreased migration rates. Furthermore, more than 60% of cell population is observed to migrate from areas of low to high structural stiffness. Additionally dividing cells are observed to round up and daughter cells are observed to migrate away from each other after division. Interestingly, dividing rounded cells are found to be anchored to the fibers through thin protrusions emanating from the focal adhesion sites. These results indicate a substrate stiffness sensing mechanism that goes beyond the traditionally accepted modulus sensing that cells have been shown to respond to previously.  From this work, the importance of structural stiffness in cellular mechanosensing at the single cell-nanofiber scaled warrants consideration of the above factors in accurate design of scaffolds in future. / Master of Science

京都大学 / 0048 / 新制・課程博士 / 博士(農学) / 甲第19027号 / 農博第2105号 / 新制||農||1030(附属図書館) / 学位論文||H27||N4909(農学部図書室) / 31978 / 京都大学大学院農学研究科森林科学専攻 / (主査)教授 大澤 晃, 教授 髙部 圭司, 教授 北島 薫 / 学位規則第4条第1項該当 / Doctor of Agricultural Science / Kyoto University / DFAM

No description available.

This study is an examination of Earl Hatch and Clair Musser's transcriptions for marimba of Chopin's Waltz, Opus 64 No. 1, Musser's arrangement of Chopin's Mazurka, Opus 17 No. 4, Hatch's setting of Brahms' Hungarian Dance No. 5, and Frank Mac Callum's treatment of Franck's "Chorale" from the Prelude, Chorale and Fugue. Additionally, the role of the transcription during the Romantic Period, the historical development of the marimba transcription, and performance considerations of the specific works presented are discussed.

An understanding of the piano transcription is basic to any proper comprehension of nineteenth-century piano music and performance practice. In this study, the transcription for solo piano is examined in relation to several musical milestones in the mid-nineteenth century, including far-reaching technical developments in the piano, the beginning and growth of the public concert, the birth of the solo piano recital, and the influence of virtuosity as a Romantic ideal. In addition, as Liszt was undoubtedly the greatest transcriber of the nineteenth century, several representative transcriptions of Liszt are analyzed and compared to their original models, including Schubert's Gretchen am Spinnrade and Auf dem Wasser zu singen, Chopin's Moja pieszczotka ("My Joys"), Wagner's Liebestod from Tristan und Isolde, and the quartet from the final act of Verdi's Rigoletto.

<p> Around 98% of the crude steel produced in the United States goes through the CC process, in which a water-cooled mold is used to solidify molten steel using water sprays to create semifinished slabs or billets. The quality of both the exterior and inside of the slab is directly related to the rate at which it is cooled, making secondary cooling a difficult process. The heat must be removed efficiently without causing the slab to crack or deform in any way. Low grade steel is produced because of inadequate spray cooling and solidification, which leads to flaws like cracking and breakout. Real-time online dynamic casting control systems are becoming increasingly popular in continuous casting as a means to increase yield and energy efficiency. These systems are built to reliably produce high-quality steel products via real-time temperature measurements and dynamic adjustment of the spray cooling rate. For real-time heat transfer and solidification calculations in the field, the key challenge is determining an accurate Heat Transfer Coefficient (HTC) for the steel product's surface. The correlations for predicting the spray cooling rate empirically have been developed with great care. Nevertheless, these correlations are only valid under specific application circumstances. Building it takes a significant amount of time and effort, and there is no assurance that the correlation will continue to accurately predict HTC even if the development process is modified in any way. An in-depth investigation into the heat transfer mechanisms that take place during the secondary cooling step of continuous steel casting is required in order to achieve control and optimization goals for this step. The non-optimized solidification process also contributes to the formation of inhomogeneous steel properties. The project required the application of computational fluid dynamics modeling techniques so that the casting process could be regulated and improved upon. Simulation of droplet formation, droplet transport, and impingement heat transfer during secondary cooling with an air-mist nozzle in a 3D computational fluid dynamics (CFD) model is going to be done in this study with the intention of generating a multivariable correlation that can accurately predict the lumped HTC under any casting condition. This will be accomplished by using the model. It modeled the solidification of the whole continuous caster by taking into consideration the impacts of roll gap, roll diameter, casting speed, and superheat in order to estimate the metallurgical length and slab temperature. This was done in order to calculate the metallurgical length </p>

As realistic virtual environments become more important, it is interesting to examine procedural generation. In this work, plausibility of virtual furniture layouts was evaluated in a perceptual study comparing layouts by a professional human interior designer with layout variants rearranged by a C# algorithm. It attached related furniture sides at specified distances in groups. Rasterized furniture footprints were tested, and layouts without overlaps between furniture or their clearance areas were accepted. The algorithm was inspired by Germer and Schwarz (Computer Graphics Forum, 28(8), pp. 2068–2078. 2009), and the evaluation methodology by Yu et al. (ACM Transactions on Graphics, 30(4), pp. 1–11. 2011). The algorithm was run by a Unity tool which placed furniture models in a virtual 3D room. Human-made layouts were also visualized and all layouts presented for 2 and 10 seconds with participants tasked to assess if they were human-made or not. The algorithm fulfilling side-based spatial relation constraints and clearance area constraints did not prove to produce as plausible virtual layouts as those by a human designer, but these constraints significantly improved the perceptual plausibility versus semi-arbitrary furniture placement with only wall-placement constraints for relevant furniture. Perceived orderliness of both human-made and generated layouts was significantly positively correlated with plausibility. The evaluation also provided knowledge of what characteristics are perceived as tells of procedural generation rather than human interior design. / Då realistiska virtuella miljöer blir viktigare är det intressant att undersöka processuell generering. I detta arbete utvärderades trovärdigheten av virtuella möbellayouter i en perceptuell studie som jämförde layouter gjorda av en inredningsdesigner med layoutvariationer omarrangerade av en C#-algoritm. Den satte ihop relaterade möbelsidor på specificerade avstånd i grupper. Rasteriserade möbelavtryck testades och layouter utan överlapp mellan möbler eller deras friytor accepterades. Algoritmen var inspirerad av Germer och Schwarz (Computer Graphics Forum, 28(8), s. 2068–2078. 2009) och utvärderingen av Yu et al. (ACM Transactions on Graphics, 30(4), s. 1–11. 2011). Ett Unity-verktyg placerade möbler i ett virtuellt 3D-rum. Designer-layouter visualiserades också och alla layouter visades i 2 &amp; 10 sekunder för deltagare som bedömde om de var arrangerade av människa eller ej. Algoritmen som uppfyllde spatiala sidorelationsvillkor och villkor för fria ytor visade sig inte producera lika trovärdiga virtuella layouter som de gjorda av en människa, men dessa villkor förbättrade trovärdigheten signifikant jämfört med semi-godtycklig möbelplacering med enbart väggplaceringsvillkor för relevanta möbler. Uppfattad nivå av ordning var för både de mänskliga och genererade layouterna signifikant positivt korrelerad med deras trovärdighet. Utvärderingen gav också kunskap om vad som uppfattas som tecken för datorgenerering snarare än mänsklig inredning.

In Spring 2007, the University of Central Florida (UCF) Department of Theatre mounted a production of "The Rocky Horror Show." This thesis focuses on the author's process of using the gospel music style to revitalize "The Rocky Horror Show," a cult musical. The author uses defining characteristics of the cult film genre to establish a set of guidelines. "The Rocky Horror Picture Show" is the movie version of the stage musical and is responsible for the show's inevitable cult status. He discusses the history and journey of "The Rocky Horror Show" and how audience participation was integral in establishing this landmark musical. The reader observes the process used in rearranging "The Rocky Horror Show" score from start to finish and recordings used as influence throughout. Although this is a discussion of a musical process, this portion of the document is written in terms for all to understand, and a glossary of terms is provided for those that are unsure of certain vocabulary. With a show that is well established, one must be careful when making stylistic changes. The author took this into consideration when arranging the score and rationalizes through a discussion of gospel music history, key gospel elements apparent throughout the score, and how the essence of Richard O'Brien's music remains intact.