This research examined the concept of base erosion and profit shifting in the context of tax schemes employed by multinational corporations. The objective of this thesis was to identify weaknesses within South Africa’s income tax legislation, based on these schemes, and further to propose recommendations to counter the occurrence of base erosion and profit shifting by multinational companies. The research also comprised of a limited review of current global and South African initiatives to address the problem of base erosion and profit shifting. It was concluded that there are a number of weaknesses in the definitions and provisions of the South African income tax legislation that need to be addressed in order to reduce base erosion and profit shifting. Brief recommendations were proposed in relation to each of the weaknesses, in order to address them.

In this project, the researcher evaluates revenue collection and allocation challenges faced by South African Municipalities in the case of NDLAMBE Local Municipality and this research project consist of five Chapters. Chapter one introduces and outlines the setting of the study and also provides the problem statement, research questions, research objectives and significance of the study. The chapter further clarifies the key concepts and terms that were used in the study, delimitation and limitations of the study. Chapter two provides a critical discussion of the concept of revenue collection and allocation, focusing on the various perspective of revenue. A source of municipal revenue and revenue collection and allocation model is explained as well as theoretical framework that guides it. Chapter three gives an account of the research design and methodology used in the study and in this study the researcher used the qualitative research approach as a data collection technique and document surveys were used because it is cheap and it saves time. The chapter also highlights the revenue collection and allocation applicable to the study and conclude by discussing the data analysis techniques that were used in the empirical study. Chapter four dealt with the data analysis of data collected presentation and discussion of the results and the researcher analyzed data using the filtering technique and content analysis. Chapter five drew conclusions and made scientific recommendations based on the research findings.The municipality is largely dependent on grants from upper spheres of government and generate less than 20 percent of current expenditures from own resources. As a whole, the revenue collection and allocation challenge of the NDLAMBE Local Municipality, given the current scenario of flows, is a reason for concern. Due to historical and political factors, local governments in South Africa differ substantially in terms of potential revenue base, but it may be that in many cases potential revenue is not exploited and that the high level of dependency on grants, high level of bad debts and lack of political will to be more self-reliant is the result of poor revenue in NDLAMBE Local Municipality.

In this project, the researcher evaluates revenue collection and allocation challenges faced by South African Municipalities in the case of NDLAMBE Local Municipality and this research project consist of five Chapters. Chapter one introduces and outlines the setting of the study and also provides the problem statement, research questions, research objectives and significance of the study. The chapter further clarifies the key concepts and terms that were used in the study, delimitation and limitations of the study. Chapter two provides a critical discussion of the concept of revenue collection and allocation, focusing on the various perspective of revenue. A source of municipal revenue and revenue collection and allocation model is explained as well as theoretical framework that guides it. Chapter three gives an account of the research design and methodology used in the study and in this study the researcher used the qualitative research approach as a data collection technique and document surveys were used because it is cheap and it saves time. The chapter also highlights the revenue collection and allocation applicable to the study and conclude by discussing the data analysis techniques that were used in the empirical study. Chapter four dealt with the data analysis of data collected presentation and discussion of the results and the researcher analyzed data using the filtering technique and content analysis. Chapter five drew conclusions and made scientific recommendations based on the research findings.The municipality is largely dependent on grants from upper spheres of government and generate less than 20 percent of current expenditures from own resources. As a whole, the revenue collection and allocation challenge of the NDLAMBE Local Municipality, given the current scenario of flows, is a reason for concern. Due to historical and political factors, local governments in South Africa differ substantially in terms of potential revenue base, but it may be that in many cases potential revenue is not exploited and that the high level of dependency on grants, high level of bad debts and lack of political will to be more self-reliant is the result of poor revenue in NDLAMBE Local Municipality.

The trust figure in South Africa has undergone an interesting process of evolution during the last century – from a mere gratuity or private tax evasion tool to a proper family protection, business entity, investment, and structured finance vehicle. Its flexibility and multi-functionality positioned the trust as an ideal legal institution for many innovative ideas in the search for holistic business structures, economic empowerment transactions, general estate planning and risk protection initiatives, and ultimately, its application as financial instrument and structured finance entity. The development of both traditional and synthetic securitisation schemes in South Africa has been investigated, with some emphasis on the application of the special purpose institution, which may be in trust form. It is submitted that the application of the trust figure has developed without any significant contribution from the local legislator. A sound legal and regulatory framework is crucial for the creation of a strong future environment for legal and financial vehicles. The question is, however, whether the current South African legal framework for the application of the business trust, and also as a vehicle for financial instruments, is adequately sound and robust in light of the standards set in the international business and financial environment. It is submitted that the hybrid nature of the South African legal landscape is conducive for the development of sound legal systems in an ever-changing legal and economic reality. It is further submitted that in the development of proper legal frameworks, South Africa should position itself particularly in its context as a Southern African developing democracy. The South African trust development is compared with that of some foreign jurisdictions as well as with international conventions and treaties of relevance. Some recommendations for necessary changes are made and it is submitted that such future development of the trust figure should not take place haphazardly, but within the context of a structured regulatory model.

The step transaction doctrine is one of the judicial doctrines used by the courts to interpret tax law. The doctrine requires that a series of transactions be treated as a single transaction if the transactions share a single, integrated purpose. Many authors believe there is a great deal of uncertainty as to when the doctrine will be applied. Uncertainty and inconsistency in the application of tax law add to the complexity of the law. One of the most complex areas of tax law is Subchapter C of the Internal Revenue Code, which governs corporate formations, redemptions, liquidations, distributions, and reorganizations. The purpose of this study was to determine if the step transaction doctrine is being consistently applied by the Tax Court and what variables affect the judges' decision in these cases. Hierarchical logit analysis was used to derive a full model and two restricted models. The full model was used to determine the predictive power of the variables that were identified and to explain the extent to which the individual variables affect the judges' decisions. One restricted model was used to test temporal stability. The other was used to test consistency when different issues of tax law are involved. The data source was the sample of step transaction cases involving Subchapter C issues decided by the Tax Court and its predecessor, the Board of Tax Appeals. Eight variables were identified to evaluate the factors discussed in the literature and major court cases involving the doctrine. Four of the variables were found to be statistically significant. The full model correctly predicted the outcome of 79.5 percent of the cases. The restricted model to test temporal stability correctly predicted the outcome of 86.3 percent of the cases. The restricted model to test the consistency of the decisions relating to a specific topic correctly predicted the outcome of 85.7 percent of the cases.

In this study, I investigate the effect of auditor-provided tax services (ATS) on firms’ levels of book-tax differences and investors’ mispricing of book-tax differences. The joint provision of audit and tax services has been a controversial issue among regulators and academic researchers. Evidence on whether ATS improve or impair the overall accounting quality is inconclusive as a result of the specific testing circumstances involved in different studies. Book-tax differences capture managers’ earnings management and/or tax avoidance intended to maximize reported financial income and to minimize tax expense. Therefore, my first research question investigates whether ATS improve or impair audit quality by examining the relation between ATS and firms’ levels of book-tax differences. My results show that ATS are negatively related to book-tax differences, suggesting that ATS improve the overall audit quality and reduce aggressive financial and/or tax reporting. My second research question examines whether the improved earnings quality for firms acquiring ATS leads to reduced mispricing of book-tax differences among investors. Recent studies document that despite the rich information about firms’ future earnings contained in book-tax differences, investors process such information inefficiently, leading to systematic pricing errors among firms with large book-tax differences. My empirical evidence indicates that ATS mitigate such mispricing, with pricing errors being lower among firms acquiring ATS compared with firms without ATS. Collectively, these results support the notion that ATS improve audit quality through knowledge spillover. Moreover, the improved earnings quality among firms acquiring ATS in turn helps reduce investors’ mispricing of book-tax differences.

This research tests for persistence in tax generated earnings changes. Earnings persistence is indicated by the capitalization of earnings by securities markets. This research disaggregates accounting earnings and examines the security markets’ evaluation of the relative permanence or transience of the component of earnings resulting from revenue law changes. Two proxies for tax generated earnings changes are evaluated though an examination of earnings response coefficients. The results indicate that tax generated earnings changes are not expected to persist beyond two accounting periods, and may reflect the ability of firms to manage tax earnings. / Ph. D.

This study compared the turnover tax and small business corporation tax systems in South Africa as applicable to micro and small businesses. Misinformed perceptions of the turnover tax system were the motivation for this study. A three phase approach was adopted to conduct this study, the phases being literature review, in-depth face-to-face interviews and quantitative analysis of financial statements which are referred to as case studies. The tax liability was calculated for each of the thirty cases and thereafter a comparative analysis was performed to establish the most beneficial tax system for each case study. The findings for year one revealed that the small business corporation tax system was the most beneficial tax system for fifteen of the thirty cases and turnover tax for the other fifteen cases. Over an average of five years, fourteen cases benefited from the small business corporation tax system and sixteen from turnover tax. There were a number of significant reasons why the above mentioned tax systems were appropriate for each of the thirty cases, one of which being, the type of business or industry where the case is located. The information obtained from this study could inform small and micro businesses about the most appropriate and beneficial tax system for their businesses. In addition the information emanating from this study could be used by tax practitioners to advise their clients on the most appropriate tax system for their businesses. Lastly, the results of this study could contribute to the debate around legislation for small and micro businesses. / Taxation / M. Com. (Accounting)

This study compared the turnover tax and small business corporation tax systems in South Africa as applicable to micro and small businesses. Misinformed perceptions of the turnover tax system were the motivation for this study. A three phase approach was adopted to conduct this study, the phases being literature review, in-depth face-to-face interviews and quantitative analysis of financial statements which are referred to as case studies. The tax liability was calculated for each of the thirty cases and thereafter a comparative analysis was performed to establish the most beneficial tax system for each case study. The findings for year one revealed that the small business corporation tax system was the most beneficial tax system for fifteen of the thirty cases and turnover tax for the other fifteen cases. Over an average of five years, fourteen cases benefited from the small business corporation tax system and sixteen from turnover tax. There were a number of significant reasons why the above mentioned tax systems were appropriate for each of the thirty cases, one of which being, the type of business or industry where the case is located. The information obtained from this study could inform small and micro businesses about the most appropriate and beneficial tax system for their businesses. In addition the information emanating from this study could be used by tax practitioners to advise their clients on the most appropriate tax system for their businesses. Lastly, the results of this study could contribute to the debate around legislation for small and micro businesses. / Taxation / M. Com. (Accounting)

The Taxpayer Service Division contributes to the Internal Revenue Service mission of achieving the highest possible voluntary compliance with the Federal income tax law by answering questions and helping taxpayers in their return preparation efforts. These services are provided by Taxpayer Service Representatives and Taxpayer Service Specialists (TSS's). The TSS position was established in 1975 to upgrade the quality of assistance provided. TSS duties include being able to provide assistance with problems involving complex areas of the tax law. The purpose of the study was to disclose to what extent TSS's are called on to answer tax questions related to partnerships, corporations, and Subchapter S corporations and to disclose whether they have been trained and are able to answer the inquiries.