Investors constantly seek to secure business ventures and structures that will provide them with the most tax-efficient consequences by utilising loopholes in tax legislation and exploiting them within the legal requirements. With the recent growing interest in the undeveloped markets in Africa, many South African companies aim to invest into Africa in a tax-efficient manner. Mauritius, being a low tax jurisdiction and having a favourable tax treaty network with a large number of African countries, is an attractive choice for South African companies wishing to set up a platform for investing into Africa. The aim of this study was to address the shortcomings of efficient tax planning and the approach to invest into Africa using Mauritius as gateway for South African resident companies. The study focused on the tax implications of an offshore trust and offshore company incorporated in Mauritius for tax-efficient investing in order to minimise taxes. Therefore this study did not focus on using Mauritius for tax evasion purposes and a qualitative approach was applied, using a hypothetical case study to determine the most tax-efficient organisational structure for minimising taxes. The findings of the study revealed that, on a balance of case law and tax legislation, a tax-minimising organisational structure is largely influenced by its residency status and South Africa‟s control foreign company (CFC) legislation. Residency for an offshore trust and offshore company will be at the place where it is effectively managed. The findings revealed that the tax consequences are similar for an offshore trust and offshore company in Mauritius legislation. However, the hypothetical case study revealed that the impact of the CFC legislation can have negative consequences for a structure where only an offshore company is used, and therefore the ideal tax-minimising structure will be where a South African company uses a combination of an offshore trust and offshore company in Mauritius in order to avoid the possibility of CFC legislation having an impact on such a structure. / Dissertation (MCom)--University of Pretoria, 2012. / Taxation / unrestricted

South Africa changed its tax system from a source-based to a resident-based system in 2001. This change is in line with tax reforms worldwide. However, over the last two decades, personal income tax reforms have not resulted in a noticeable increase in tax revenue worldwide, even though governments find themselves hard-pressed to maintain or increase their expenditure. The aim of this study was to compare the South African tax base, which relies on taxing individuals, with the tax base used in another developing country, namely India, as well as to those applied in two developed countries, namely the United Kingdom (UK) and the United States (US). This comparison identified similarities and differences between the countries, and highlighted possible improvements to South African tax legislation in order to broaden the country‟s tax base and potentially increase tax revenues. For the purposes of the study, a tax base can be defined as the total income of an individual, after allowing for specified deductions, allowances and other adjustments, on which tax is levied. It was determined that the tax base used in South Africa is similar in some respects to those used in India, the UK and the US. An improvement that South Africa could adopt is the inclusion of the annual value of house property, as specified in the Indian tax system. The employment abroad exclusion from income could be replaced by a foreign-earned income exclusion, as applied in the US tax system. It was also determined that permitting certain deductions could in fact increase the tax base, as these deductions could entice taxpayers to register for tax, therefore increasing tax compliance and ultimately increasing tax revenue. By adopting any of the advantages of the other tax systems, South Africa can broaden its tax base and generate additional tax revenue to support the government‟s needs. / Dissertation (MCom)--University of Pretoria, 2013. / gm2014 / Taxation / unrestricted

MPH / Department of Public Health

Neisseria meningitidis infection in humans usually manifests as meningitis and septicemia with skin manifestations. Infections of the respiratory tract with N meningitidis have been documented in the past, but often this organism is not routinely considered in the differential diagnosis of pneumonia. The pathogenic role of N meningitidis in lower respiratory tract infections may be underestimated because its isolation is difficult, particularly when oropharyngeal flora are present. We profile 2 elderly patients with primary meningococcal pneumonia to show the importance of Gram stain and culture in early diagnosis. These modalities helped guide treatment and prophylactic measures.

Resident cardiac Sca-1-positive (+) stem cells may differentiate into cardiomyocytes to improve the function of damaged hearts. However, little is known about the inducers and molecular mechanisms underlying the myogenic conversion of Sca-1+ stem cells. Here we report that sphingosylphosphorylcholine (SPC), a naturally occurring bioactive lipid, induces the myogenic conversion of Sca-1+ stem cells, as evidenced by the increased expression of cardiac transcription factors (Nkx2.5 and GATA4), structural proteins (cardiac Troponin T), transcriptional enhancer (Mef2c) and GATA4 nucleus translocation. First, SPC activated JNK and STAT3, and the JNK inhibitor SP600125 or STAT3 inhibitor stattic impaired the SPC-induced expression of cardiac transcription factors and GATA4 nucleus translocation, which suggests that JNK and STAT3 participated in SPC-promoted cardiac differentiation. Moreover, STAT3 activation was inhibited by SP600125, whereas JNK was inhibited by β-cyclodextrin as a lipid raft breaker, which indicates a lipid raft/JNK/STAT3 pathway involved in SPC-induced myogenic transition. β-Catenin, degraded by activated GSK3β, was inhibited by SPC. Furthermore, GSK3β inhibitors weakened but the β-catenin inhibitor promoted SPC-induced differentiation. We found no crosstalk between the lipid raft/JNK/STAT3 and β-catenin pathway. Our study describes a lipid, SPC, as an endogenic inducer of myogenic conversion in Sca-1+ stem cells with low toxicity and high efficiency for uptake.

Cardiac stem cells (CSCs) have emerged as promising cell candidates to regenerate damaged hearts, because of the potential in differentiating to cardiomyocytes. However, the differentiation is difficult to trigger without inducers. Here we reported that β-cyclodextrin (β-CD) increased the expression of cardiac transcription factors (Nkx2.5 and GATA4), structural proteins (cardiac Troponin T, cTnt), transcriptional enhancer (Mef2c) and induced GATA4 nucleus translocation in adult resident CSCs, thus β-CD could be used to enhance myogenic transition. As the differentiation process was accompanied by autophagy, we constructed the Atg5 knockdown cell line by using the Atg5 siRNA lentivirus, and the myogenic conversion was blocked in Atg5 knockdown cells, which suggested that β-CD induces the cardiomyocytes transition of resident CSCs through autophagy. Furthermore, we found that JNK/STAT3 and GSK3β/β-catenin was the downstream pathways of β-CD-induced autophagy and differentiation using the inhibitors. Moreover, β-CD performed its functions through improving intracellular cholesterol levels and affecting cholesterol efflux. Collectively, our results reveal that β-CD as a novel tool to induce myogenic transition of CSCs, which could mobilize the resident CSCs or used together with CSCs to enhance the therapy effects of CSCs on damaged hearts. In addition, the clarified molecular mechanisms supported the new targets for inducing cardiomyocyte differentiation.

The combined effect of land-use alterations and introduced diffuse anthropogenic pollutants to the earth's surface in suburban/urban zones often sparks a decrease in stormwater quality in the area, and contributes to nonpoint source pollution in receiving waters. The ponds at the Utah Botanical Center (UBC) located in Kaysville, UT, regularly experience algal blooms, which in turn cause low dissolved oxygen levels in the waters, indicating high concentrations of inflowing pollutants. The goal of this thesis paper was to describe the findings from the water quality monitoring implemented at both the inlet and outlet of the UBC ponds in order to assess pollutant loading to the ponds. A survey was mailed to the homeowners in the drainage area with the intention of gaining a baseline understanding of residents' perceptions of stormwater issues, and their lawn care practices that might influence stormwater quality. Results from the weekly monitoring found that the TN, TP and TSS levels were all below respective medians reported for urban areas around the United States. Baseflow separation calculations revealed that 47% of inflow was due to precipitation falling onto the watershed and therefore 53% of inflow was a product of non-stormflow. With only 47% of the inflow coming from local runoff, potential effectiveness of educational efforts was considered minimal. Survey results reported that 86% of respondents had never received educational materials regarding stormwater. Second, fertilizer is used by 92.3% of respondents and in most cases, homeowners perform more than one application per year. Of the respondents, 98.1% of them believed that individual residents had an impact (positive or negative) on the quality of water resources in the area. No significant association was found between the education component of the survey and whether participants undertook certain stormwater-related behaviors.

The purpose of the study was to determine if a relationship exists among opinions toward fluoridation of public water supplies, income, and level of education of the people of Salt Lake City, Utah. There were also two secondary concerns. One was to determine if a relationship exists between opinions toward fluoridation and other controversial social issues. The issues identified for investigations were: (1) the Supreme Court decision on abortion, (2) the Equal Rights Amendment, and (3) capital punishment. The second was to determine the factors on which opinions regarding fluoridation were based. The results of the data that was collected indicated that the higher the education level of the population the higher the probability of a favorable opinion about fluoridation. The lower the education level of the population the higher the probability of an opinion of opposition to fluoridation. (2) If the subjects yearly income was $20,000 or more there was an increased likelihood of a favorable opinion of fluoridation. If the subjects yearly income was less than $20,000, there was a greater likelihood that the opinions would be in opposition to fluoridation. (3) A majority of the subjects opposed the Supreme Court ruling on abortion and the Equal Rights Amendment. A majority favored reinstatement of capital punishment. Interpreted, this was felt to reveal a tendency of the subjects to adopt a conservative stand on controversial social issues.

京都大学 / 0048 / 新制・課程博士 / 博士(地球環境学) / 甲第19873号 / 地環博第147号 / 新制||地環||29(附属図書館) / 32909 / 京都大学大学院地球環境学舎環境マネジメント専攻 / (主査)教授 岡﨑 健二, 准教授 小林 広英, 准教授 ｼﾞｪｰﾝ ｼﾝｶﾞｰ / 学位規則第4条第1項該当 / Doctor of Global Environmental Studies / Kyoto University / DFAM

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