"The Income Tax Acts themselves impose a territorial limit; either that from which the taxable income is derived must be situate in the United Kingdom or the person whose income is to be taxed must be resident there", per Lord Herschell in Colquhoun v Brooks (1889) 2 TC 490 at 498 These remarks by Lord Herschell even though directed at the United Kingdom tax system in 1889 seem to capture the situation in the new tax law in Lesotho. A recurring question for any tax system to date is is taxation by either residence and/or source appropriate? This question inspired my research into the examination of the new Lesotho Income Tax Order No 9 of 1993.

This thesis looks at legal mechanisms allowing the non-collection of tax debts in the tax systems of Canada and the United States. The goal is to shed light on the choices made in Canada’s tax collection system by juxtaposing it with the American system. The comparison reveals differences in the ways in which the two jurisdictions allow taxpayers to participate in the tax system and differences in how the two jurisdictions choose to make decisions about the forgiveness of tax debts. Although Canada has generally rejected the idea of compromise within the tax system, there is a tax policy case to be made in favour of the compromise of tax debts in certain situations.

M.Com. (Taxation) / Please refer to full text to view abstract

Includes bibliographical references (leaves 138-139). / By comparing the income tax allowances and deductions for private investors in film production funds in Germany and in South Africa, the author aims to show how the governments of these two countries are taxing private individuals who invest in film funds, i.e. what incentives are offered to such venturesome investors. The tax incentives examined here provide the taxpayer with a deferment of his tax payments. By making the comparison the author intends examine what role a domestic film fund can play as an instrument for financing domestic and export films and how the government can promote film production in this way.

No description available.

Section 20 of the Income Tax Act, No 58 of 1962 allows a taxpayer that has sustained an assessed loss to carry forward the balance of assessed loss and be set off against income earned in the future years. In addition, the loss sustained from one source may be set off the income from another. The assessed loss may be carried forward indefinitely, provided the taxpayer does not fall foul to a provision that restricts the continued use of the assessed loss. The taxpayer's right to retain, carry forward and utilise the assessed loss will be lost if: • The taxpayer's debt(s) are reduced or extinguished, without it being settled. • When a company cease trading. • Also in the case of a company, when income is channelled into it solely for the utilisation of the assessed loss. A recent amendment prevents certain individuals from setting off the assessed loss sustained in certain activities against the income of another. / Thesis (M.Com.)-University of KwaZulu-Natal, Westville, 2004.

LL.M. / Please refer to full text to view abstract

M.Com. / Please refer to full text to view abstract

M.Com. / Please refer to full text to view abstract

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation) Johannesburg, 2017 / As a result of a weakening and slow global economy and rising debt, many foreign governments are finding it difficult to implement strategies to ensure continued inclusive and sustainable growth. It is based on this troubling perspective of global uncertainty that tax authorities worldwide have unanimously persisted in their fight against tax evasion through the under-declaration of income from foreign assets, the illegal movement of money abroad, the misapplication and / or manipulation of transfer pricing legislation and mistreatments of tax treaties. The G20 Leaders together with the Organisation for Economic Co-operation and Development (“OECD”) have developed standards such as the Common Reporting Standard (“CRS”) for the Automatic Exchange of Information (“AEOI”) between tax authorities to enhance the sharing of information and transparency of information between tax authorities worldwide. South Africa has pledged to implement the CRS and automatically share tax information with other jurisdictions on an annual basis in the fight against tax evasion and avoidance. Of significance, in terms of timing for South African tax residents, is that South Africa has undertaken to be one of the early adopters of the CRS and committed to commence the first exchange of information from 2017. In light of the standards and actions coming into place, it has become clear that before long the likelihood of the South African Revenue Services (“SARS”) and the South African Reserve Bank (“SARB”) detecting tax evasion and avoidance is increasingly high. Based on this, non-compliant taxpayers have a limited timeframe to manoeuvre freely in and what may be their last opportunity to voluntarily disclose these assets and the income derived therefrom to SARS and SARB without facing heavier penalties and possible criminal prosecution. / MT 2018