Thesis (M. Econ.)--University of Hong Kong, 1994. / Declaration statement inserted. Includes bibliographical references (leaves 91-93).

Thesis (Ph. D.)--University of Wisconsin--Madison, 1959. / Typescript. Vita. eContent provider-neutral record in process. Description based on print version record. Includes bibliographical references (leaves 212-220).

Thesis (M.Econ.)--University of Hong Kong, 1994. / Includes bibliographical references (leaves 91-93). Also available in print.

Inaug.-diss.--Heidelberg. / Lebenslauf. "Literaturverzeichnis": 1 p. following p. vi.

Thesis (Ph. D.)--University of Wisconsin--Madison, 1970. / Typescript. Vita. eContent provider-neutral record in process. Description based on print version record. Includes bibliographical references.

Thesis--Wisconsin. / Vita. Includes bibliographical references (leaves 142-144).

Thesis (Ph. D.)--The University of Wisconsin--Madison, 1972. / Typescript. Vita. eContent provider-neutral record in process. Description based on print version record. Includes bibliography.

The Report of the Royal Commission on Taxation, 1967, stated that tax treatment of leases was of great concern if the system of capital cost allowances was not to be undermined. In spite of this warning, nothing has been done since the repeal of former Section 18 of the Canadian Income Tax Act, in 1963, to remedy the situation. Section 18 was repealed because it was found to be administratively inoperable. A study of current accounting and business practice, of theoretical and research committee recommendations, and of legislation in the United States appears to isolate the reason for legislative difficulties. The premise on which Canadian legislation was based is much too narrow. Only those leases which had purchase options were dealt with. In fact, most long term leases, regardless of whether or not they have purchase options, have most of the attributes of purchases. These attributes include property rights acquired in assets, useful life of assets, equity accumulation in assets, and the fair -market value of assets in relation to the present value of total payments required under the lease. In most long term leases, the present value of contract payments, including options, comprises the major part of the fair market value. Current opinion and practice, as expressed by most writers, by research committees, and as evidenced by accounting practice and business acceptance in balance sheet footnoting of long term leases, effectively treats such acquisition as quasi-purchases. In this regard, both theory and practice is far ahead of legislation. The inequity in the tax treatment of long term leases is much more consequential than is generally realized. Not only is there substantial tax postponement for an ever burgeoning number of realty and equipment leases, but there is 'proper' tax avoidance under the long term lease through depreciation of land for tax purposes, effectively available to lessees, but not available to purchasers. When the thousands of service station and supermarket outlets, and the fact that most are under long term lease in Canada, are considered, tax avoidance from this source alone amounts to many, many, millions of dollars annually. Since leasing is always initially more expensive than purchasing, and the major reason for many leases is tax advantage, it is not unfair to say that legislative inaction contributes considerably to business inefficiency. This taxation problem is examined under varying aspects, including historical applications of the Canadian Income Tax Act; present legislation and its effectiveness; pertinent tax cases in Canada and in the United States; current accounting and business trends, and Carter Report suggestions. Finally, suggested legislation which embodies the transition of long term leasing to purchasing is proposed. While the proposed solution is relatively simple and concise, it is supported by theory, by practicality, and by operability. / Business, Sauder School of / Graduate

A research report submitted to the Faculty of Commerce, Law and Management in partial fulfilment of the requirements for the degree of Master of Commerce specialising in Taxation / Taxpayers are broadly financed in two ways, namely through the use of debt and equity. The returns on capital and debt are treated differently from an income tax perspective (SARS 2013). The interest expense incurred by taxpayers in the production of income by a person carrying on a trade, are deductible in determining taxable income, subject to certain conditions and limitations. The number of provisions contained in the Income Tax Act of 1962 (the Act) which deal with the tax treatment of interest income and interest expenditure have gradually increased over time. There are numerous aspects to be borne in mind by resident and foreign companies when considering the income tax and withholding tax implications which may arise in respect of transactions giving rise to interest income and interest expenditure (SAICA 2015). This is affirmed by the number of provisions in the income tax act dealing with the deductibility of interest primarily dealt with in section 24J of the Act as well as indicated by the 2014 amendments to section 8F, the introduction of section 8FA, sections 23M and 23N into the legislation. The purpose of this report is to assess whether the Department of National Treasury (National Treasury) have taken the number of provisions of the deductibility of interest too far. / NG (2020)

In light of the provisions of the Tax Administration Act, No 28 of 2011 (TAA), as well as the introduction of Tax Information Exchange Agreements (TIEAs) between South Africa and other nations around the world, the issues around information exchange and the confidentiality thereof has become pertinent. Article 26 of the Organisation of Economic Co-operation and Development (OECD) Model Tax Convention on Income and on Capital provides a standard for information exchange and also highlights the use of automatic exchange of information as being considered a standard form of information exchange. The recent case of Commissioner of South Africa v Werner Van Kets dealt with the definition of a taxpayer as well as information exchange. In addition, this case ruled on the hierarchy of domestic laws and international agreements. This case has led to the question of whether or not a third party is considered a taxpayer in terms of international tax agreements and raises question regarding the taxpayer's rights to confidentiality relating to information exchanged. In light of new international best practice, domestic legislation and case law, various domestic laws of South Africa were reviewed to determine whether the domestic law allows for the international exchange of information and whether or not the confidentiality clauses therein are contradictory to one another. When reviewing the manner in which South Africa allows for the exchange of information, in light of the standard Article 26, it was found that the TIEAs are aligned with both the TAA and Article 26 in terms of the exchange of information that is relevant to domestic laws. It would however appear that South Africa has not yet adopted the use of automatic exchange of information - apart from the Foreign Account Tax Compliance Act (FATCA) Inter-Governmental Agreement (IGA) that was signed with the USA. South Africa has only entered into bilateral agreements which allow for the exchange of information on request and The TAA is silent on automatic exchange, despite the financial benefit of increased annual taxation revenue that South Africa could gain through having automatic exchange agreements in place.