Thesis (M.S.)--University of Wisconsin--Madison, 1967. / eContent provider-neutral record in process. Description based on print version record. Includes bibliographical references.

The term ‘beneficial ownership’ is included in numerous tax treaties that are concluded between countries today but the majority of these treaties do not define the term. The purpose of this study is four fold. Firstly, to investigate what the meaning is of the term ‘beneficial owner’ for tax treaty purposes? Secondly, what factors should be taken into account to determine the beneficial owner, if any? Thirdly, what the meaning of the term ‘beneficial ownership’ is in the context of those tax treaties where the term has been incorporated, and lastly, if the term ‘beneficial owner’ should have a domestic law, international tax or tax treaty meaning? The study was conducted by reviewing various articles, opinions, court cases and government publications, that deals with the issues raised in the preceding paragraph, and then to identify if there are answers to these questions that were raised? The study concludes that there is no concrete on-line definition for the term “beneficial owner” and that various factors need to be considered in support of the term. The Chinese revenue authority has recently issued various circulars, setting out various factors that need to be considered in an attempt to identify the beneficial owner. Equally important is the factors that need to be considered as set out in the ‘Limitation on Benefits’ clause that appears in most US tax treaties. The study also concludes that the findings of the Court in the Indofood International Finance Ltd v JP Morgan Chase Bank NA regarding the fact that the term ‘beneficial owner’ should have an international fiscal meaning is appropriate. Although there are counter arguments supporting the fact that an domestic tax law meaning pertaining to the specific taxes should prevail over any other meaning or that the term should be interpreted in a purely treaty framework, and not be referenced to domestic law, where there is a well established international law meaning for the term, an international fiscal meaning will result in a more consistent interpretation between Contracting States and limit misinterpretation due to differences in tax and legal systems. AFRIKAANS : Die term ‘voordelige eienaar’ is ingesluit in menige belasting ooreenkomste wat tussen lande gesluit word vandag, maar die meerderheid van hierdie ooreenkomste, definieer nie die term ‘voordelige eienaar’ in die ooreenkoms nie. Die doel van hierdie studie is vier voudig. Eerstens, om vas te stel wat die betekenis van die term ‘voordelige eienaar’ vir belasting ooreenkoms doeleindis is. Tweedens, watter faktore inaggeneem moet word in die vasstelling van die betokens van die term ‘voordelige eienaar’, indien enige. Derdens, wat die betekenis van die term ‘voordelige eienaar’ is in die belasting ooreenkomste waar die term reeds geïnkorporeer is en laastens, of die term ‘voordelige eienaar’ ‘n nasionale, internasionale of belasting ooreenkoms betekenis moet hê. Die studie is uitgevoer deur artikels, opinies, hofsake en regering’s publikasies te hersien, wat met die vrae wat in die vorige paragraaf aangespreeks is handel, en om dan te identifiseer of daar antwoorde is op die vrae wat geopper is? In die die studie wat gedoen is is gevind dat daar tans geen vaste een-lyn definisie is vir die term ‘voordelige eienaar’ nie, en dat menigde faktore inaggeneem moet word ter ondersteuning van die term. Die Chinese Belastingowerheid het onlangs menigde Omskrywings uitgereik wat menigde fatore uiteensit wat oorweeg moet word in ‘n poging om die voordelige eienaar te identifiseer. Ewe belangrik is die faktore wat oorweeg moet word soos uiteengesit in die ‘beperking op voordele’ klousule wat in meeste Verenigde State van Amerika belasting ooreenkomste voorkom. Die studie het ook gevind dat die bevinding deur die Hof in die “Indofood International Finance Ltd v JP Morgan Chase Bank NA” saak rakende die feit dat die term ‘voordelige eienaar’ ‘n internasionale fiskale betekenis moet he toepaslik is. Alhoewel teen argumente ter ondersteuning is van die feit dat ‘n nasionale belasting wetgewing betekenis rakende die spesifieke belasting voorkeer moet kry bo enige ander mening van die term ‘voordelige eienaar’ of dat die term uitsluitlik in ‘n belasting ooreenkoms hoedanigheid geïntreperteer moet word, en nie moet verwys na nasional wetgewing waar daar reeds ‘n goed gevestigde internasionale wetgewing betekenis vir die term is nie, sal ‘n internasionale fiskale betekenis ‘n meer konsekwente interpretasie tussen Kontrakterende State tot gevolg hê en die verkeerde interpretasie as gevolg van verskille in belasting sisteme en wetgewing voorkom. / Dissertation (MCom)--University of Pretoria, 2010. / Taxation / unrestricted

No description available.

No description available.

Digitized by Kansas Correctional Industries

Call number: LD2668 .T4 1958 Y68

Thesis (M.Com. Taxation) -- University of Witwatersrand, Faculty of Commerce, School of Accountancy, 2014. / The taxation of dividends at shareholder level has been the norm in the majority of the international market. South Africa is a developing country that is constantly increasing its market share in the international stage and in order to be more competitive in the international market South Africa has to align itself with international norms and practices and this resulted, amongst other things, with the introduction of dividends tax in 2012. This study analysed the new dividends tax legislation that became effective on 1 April 2012 in South Africa, by way of a normative literature review, and briefly discusses how South Africa compares with Russia, India and China, three other developing countries. The literature review confirmed the benefits with regards to the dividends tax system; however, the review also confirmed that there are challenges within the dividends tax system. The benefits of the dividends tax system that were noted include amongst others; aligning South Africa with international tax norms, the increased tax base and the establishment of a familiar withholding tax system that can attract more foreign investment. The levying of dividends tax on beneficial owners results in an increased tax base because the number of taxpayers increases to companies and individuals, versus levying secondary tax on companies only on the companies paying the dividend. Some of the challenges of the dividends tax system are the administrative burden placed on companies and regulated intermediaries, the rate of 15% might be considered to be too high in comparison to other developing countries and the taxation of dividends in the hands of the individuals might be a disincentive to invest in equity shares. South African legislation on dividends tax differs from that of China; with the latter country taxing the dividends in the hands of the beneficial owners without a requirement on company‘s paying the dividend to withhold the dividends tax. The Russian legislation on taxation of dividends is similar to that of South Africa but taxes the dividend on the net amount. In India the dividend distribution tax is levied in the company making a dividend distribution.

Naturalists, state administrators and farmers in France and its colonies developed a myriad set of techniques over the course of the long eighteenth century to manage the circulation of useful and harmful insects. The development of normative protocols for classifying, depicting and observing insects provided a set of common tools and techniques for identifying and tracking useful and harmful insects across great distances. Administrative techniques for containing the movement of harmful insects such as quarantine, grain processing and fumigation developed at the intersection of science and statecraft, through the collaborative efforts of diplomats, state administrators, naturalists and chemical practitioners. The introduction of insectivorous animals into French colonies besieged by harmful insects was envisioned as strategy for restoring providential balance within environments suffering from human-induced disequilibria. Naturalists, administrators, and agricultural improvers also collaborated in projects to maximize the production of useful substances secreted by insects, namely silk, dyes and medicines. A study of these scientific and administrative techniques will shed light on how scientists, administrators and lay practitioners in the French Enlightenment came to assess and manage the risks and opportunities afforded by the related processes of commercial and ecological globalization.

Since 1970, U.S. Army Corps of Engineers, Galveston District, has been using dredged sediments from the Houston ship channel to create and restore salt marshes in Galveston Bay. Some projects have failed due to excessive sediment erosion or siltation. The research reported here applies an engineering approach to analysis of tidal creeks in natural and beneficial use marshes of Galveston Bay. The hydrodynamic numerical model, DYNLET, was used to assess circulation in marsh channels. A preliminary sediment transport model was developed to analyze erosion and deposition for the same channels. In situ flume experiments were conducted to determine the sediment erodibility in natural and constructed marshes. A natural reference marsh, Elm Grove, was studied to understand marsh hydrodynamics and model calibration. The model results show that DYNLET can largely duplicate the marsh hydrodynamics and the sediment transport model can provide preliminary indication of erosion in tidal creeks. Analysis of the preliminary channel layout of the beneficial-use marsh demonstrated that channels will have sufficient circulation and optimum velocities.

In a time when interdependence in business becomes more prevalent and necessary to maintain and sustain competitive advantage, understanding the mechanisms by which businesses relate and collaboratively adapt become central to collaborative growth and mutual success. Learning becomes central to the adaptive process. Interorganizational learning is an often challenging result of collaborative efforts. The more different the organizations are from one another, the more challenging the adaptive process and interorganizational learning. This writing addresses some of the complexities involved in collaborative learning of organizations with divergent goals through the lens of exploration exploitation phenomena. It further addresses how interorganizational learning happens between organizations that are private and public in nature. This writing is a case study that answers the question of how organizations working in collaboratives learn from each other to attain mutually beneficial results by examining two such entities in a government and private partnership. This study extends concepts of interorganizational learning as well as provides guidelines for business entities seeking to attain or sustain learning organizations. It also provides a framework from which government entities may work synergistically with private enterprise to provide competitive service to their respective demographic.