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.

Tesis (licenciatura en contador público y auditor)--Universidad de San Carlos de Guatemala. / Bibliography: p. 99-[100].

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 Section 18 was repealed because it was found to be administratively inoperable.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

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.

Bibliography: pages [115]-120. / This thesis establishes a group income tax system for South Africa so that equity may be achieved between the burden of company income tax borne by shareholders who invest in companies that are structured through subsidiaries and shareholders that invest in companies that are structured through divisions. For example, intercompany profits and losses of a revenue nature are subject to income tax whereas interdivisional profits or losses of a revenue nature are not subject to income tax. Also, tax losses incurred by a company are not deductible from taxable income of other companies within the same group whereas in the case of a company that is structured through divisions losses incurred by a division are deductible from income of other divisions of the same company. The study is classified as 'microcomparison' whereby legal problems that exist in one country are studied on a comparative legal basis. Accordingly, the objective of the thesis is achieved by undertaking a comparative study of group income tax law in the United Kingdom and United States of America for equitable group income tax treatment of problems that exist within the current South African company income tax system. First, the definition of 'a group' is established, after which a group income tax treatment of group transactions and tax losses is established to eliminate the inequities that are inherent in the South African income tax system. Throughout the study it is demonstrated that these inequities exist in spite of the current income tax avoidance provisions (for example s103 and the connected persons rules). The conclusions made in the study indicate that the inequity that exists in the South African company income tax system should be eliminated.

No description available.

No description available.

The purpose of this study is to analyze the system of personal income taxation in Nigeria, especially with respect to its administration, equity, and effects on efficient resource usage. There have, in the past, been numerous complaints that the personal income tax in Nigeria does not yield enough revenue for the state governments, primarily because of widespread avoidance and evasion of the tax, especially by persons who do not derive income from wages and salaries. This study examines this problem in light of questions as to how the tax evolved, how important it is to state governments, how efficient and equitable it is, what administrative problems it faces, and what reforms can be implemented to best solve existing problems.

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

Advertising plays a distinct role in economies around the world and, in this regard, diverse countries have been investigated in this study including the BRICS countries. It focused on the classification of advertising cost for tax purposes. Research questions posed by this study are answered through the development of a classification process that may assist with the classification of advertising cost for the purpose of taxation. It has been established that guidelines for the classification of advertising cost as capital or revenue of nature are needed to correctly classify advertising cost for tax purposes. Furthermore, the determination of when advertising cost will be regarded as capital of nature is required. The study used a mixed method research approach, involving a literature review of case law and income tax acts as well as an analysis of annual financial statements. Findings from this research indicate a growing trend in revenue generated from advertising in South Africa; proving the importance of the advertising market in the economy. Guidelines for the classification of advertising cost for tax purposes were established by using principles from national and international case law. / MCom (Accountancy)--North-West University, Vaal Triangle Campus, 2015