Since the declaration of South Africa as the Gateway to Africa in 2010 by National Treasury, various changes have been made to South African legislation to make South Africa more attractive to foreign investors looking to expand their operations into Africa. The headquarter company regime was introduced with the purpose to provide a base from which these investments may be managed. From a tax perspective this regime eliminates or reduces specific taxes or rates of taxes for companies who elect to be classified as headquarter companies, provided that certain requirements are met. These requirements refer specifically to investments in qualifying foreign companies. The reference to foreign companies inevitably requires that the resident definition be considered. In South Africa residence of a person other than a natural person is the place where the company is incorporated, formed or established or the place of effective management which is a term subject to various interpretations. Regardless of the differences, all the interpretations refer to a senior level of management. Foreign incorporated companies with their place of effective management in South Africa are excluded from the definition should they qualify as controlled foreign companies with foreign business establishments subject to a high level of tax if the place of effective management is disregarded. The lack of skills in African countries as a product of shortfalls in the quality of education result in challenges to establish appropriately skilled management teams in these countries. When a centralised management team is set up at the headquarter company in South Africa the African subsidiaries risk being resident in South Africa and therefore the structure would not qualify for the benefits of the headquarter company regime. Further challenges arise when the exclusion to the resident definition is applied as shares held by a headquarter company are disregarded when the controlled foreign company status of the subsidiaries are determined. Therefore it is recommended that the headquarter company legislation be changed to correspond with successful regimes such as the Luxembourg and the Netherlands in that it does not only apply to foreign investment. It is further recommend that the resident definition be changed to exclude from the place of effective management test group structures that would comply with section 9I should the test be disregarded. / MCom (South African and International Tax), North-West University, Potchefstroom Campus, 2014

Since the declaration of South Africa as the Gateway to Africa in 2010 by National Treasury, various changes have been made to South African legislation to make South Africa more attractive to foreign investors looking to expand their operations into Africa. The headquarter company regime was introduced with the purpose to provide a base from which these investments may be managed. From a tax perspective this regime eliminates or reduces specific taxes or rates of taxes for companies who elect to be classified as headquarter companies, provided that certain requirements are met. These requirements refer specifically to investments in qualifying foreign companies. The reference to foreign companies inevitably requires that the resident definition be considered. In South Africa residence of a person other than a natural person is the place where the company is incorporated, formed or established or the place of effective management which is a term subject to various interpretations. Regardless of the differences, all the interpretations refer to a senior level of management. Foreign incorporated companies with their place of effective management in South Africa are excluded from the definition should they qualify as controlled foreign companies with foreign business establishments subject to a high level of tax if the place of effective management is disregarded. The lack of skills in African countries as a product of shortfalls in the quality of education result in challenges to establish appropriately skilled management teams in these countries. When a centralised management team is set up at the headquarter company in South Africa the African subsidiaries risk being resident in South Africa and therefore the structure would not qualify for the benefits of the headquarter company regime. Further challenges arise when the exclusion to the resident definition is applied as shares held by a headquarter company are disregarded when the controlled foreign company status of the subsidiaries are determined. Therefore it is recommended that the headquarter company legislation be changed to correspond with successful regimes such as the Luxembourg and the Netherlands in that it does not only apply to foreign investment. It is further recommend that the resident definition be changed to exclude from the place of effective management test group structures that would comply with section 9I should the test be disregarded. / MCom (South African and International Tax), North-West University, Potchefstroom Campus, 2014

Ämnet som denna studie behandlar är nyanländas integrering i det svenska samhället. Det framställs ett samhälleligt problem som teorier konkluderar är en följd av ett organisatoriskt problem bland de involverade parterna inom etableringsreformen. Syftet med denna uppsats är att studera hur de samverkande myndigheterna och kommunerna arbetar för att påverka nyanländas integrering och etablering i samhället, samt huruvida användningen av starkare styrmedel skulle påvisa sig bidra till en effektiv integrering av nyanlända. Två utvalda kommuner och samtliga myndigheter, förutom Migrationsverket, har intervjuats för att besvara på uppsatsens frågeställningar. Resultatet pekar på en god samverkan mellan parterna samtidigt som det även förekommer otydlighet kring ansvarsfördelning och arbetsuppgifter. Med tidigare erfarenheter som utgångspunkt kan det hävdas att det finns en stor sannolikhet att starkare styrmedel skulle kunna vara en effektiv åtgärd i att integrera nyanlända genom att förhindra att en stor andel nyanlända flyttar till segregerade områden där det inte råder goda förutsättningar för integration. / The following study deals with the integration of new arrivals in Sweden. A societal problem is depicted which theories conclude is the result of an organizational problem among the partners in the establishment reform. The purpose of this essay is to study how the collaborating authorities and municipalities work together to influence the integration and establishment of new arrivals and also whether the use of more forceful means of actions would prove to contribute to an effective integration of newcomers. Two designated municipalities and all administrative authorities, with the exception of the Swedish Migration Agency, were interviewed to answer the essay questions. The results point towards a good cooperation between the parties; however, a lack of clarity of the partners' responsibilities and duties has been found. With previous experiences as a basis it can be argued that there is a high probability that the usage of more forceful means of actions could be an effective means of integrating newcomers by preventing large proportions from moving to segregated areas, where poor conditions for integration is prevalent. The study is written in Swedish.

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While it is an undeniable historical fact that Buddhism has spread far beyond India, adapting to local circumstances and spawning new variations in the process, the process by means of which it did so is obscure. Recent scholarship has shown that to impute a sense of"mission" to Buddhism is to employ a specifically Christian category which does not fit in well with Buddhism as it was understood by the originators of the Buddhist tradition. For this and related reasons, contemporary scholars of religion prefer to speak of the "transplantation" of Buddhism rather than of "mission''. This work builds on the theories of religious transplantation advanced by Michael Pye, Frank Whaling, Martin Baumann and others. It presents a theoretical perspective on the transplantation of Buddhism that is based on an understanding of Buddhism as consisting of three interrelated "traditions" ranging from the direct perception of reality as Buddhism understands and defines it, to participation in popular Buddhist ritual. The interaction between these three traditions gives rise to four chronologically distinct, but always interacting phases in the transplantation process. The theoretical perspective is demonstrated with reference to Buddhist history in general and South African Buddhist history in particular, and by applying it to various problematic situations in contemporary Buddhism, such as the relation between Buddhism and "other" religions and the predominance of middle-class members (which in South Africa equates to white members) in contemporary western Buddhism. / Religious Studies and Arabic / D.Litt. et Phil. (Religious Studies)

The study aimed to develop an in-depth understanding of the challenges faced by social workers rendering Occupational Social Work (OSW) services, particularly in establishing and maintaining workplace support groups for employees living with HIV and AIDS. The study used a qualitative research approach, aided by exploratory, descriptive and contextual research design. Data was collected from eight participants with semi-structured interviews and was analyzed by applying eight steps for data analysis as proposed by Tesch, cited in Creswell (2003:191). Data verification was done by applying Guba’s model (in Krefting, 1991). The themes, which emerged from the interviews, were: the recruitment of members in workplace support groups and the challenges faced by social workers rendering OSW services. The findings indicate that, critical as their roles may be, social workers experience numerous challenges when providing workplace HIV and AIDS support groups. These include HIV and AIDS disclosure, management, organisational and logistical challenges / Social Work

<p>In this essay we map and evaluate obstacles and problems that can occur during the establishment of international companies in Russia. This is done by investigating Swedish companies, which are established in Moscow and Saint Petersburg. We used secondary and primary data from books, previous surveys, reports, articles and the Internet. We also interviewed the following companies: Alfa Laval, Kockum Sonics AB, Höganäs Keramik, Skanska, Assa Abloy, Advakom, AnoxKaldnes, Lindab, Delovoj Peterburg, HL-Display and also a journalist from the Swedish Radio.</p><p>Most of the problems named by the interviewees were similar, but some differences were also found. The differences were primarily found in the ranking of importance between the different problems. As a conclusion we can say that the most important factors were:</p><p>· crime such as bribery</p><p>· administrative problems such as licensing</p><p>· tax laws and political system</p><p>· culture and language.</p><p>These problems can however be avoided to some point by hiring Russian consultants to manage the contacts and agreement.</p>

Recent research has challenged the long-standing hypothesis that forests in the Upper Midwest of the United States developed during wetter periods and retreated during dry periods. We explored this debate by examining patterns of tree establishment on an oak savanna in east-central Minnesota within the context of variable moisture availability and fire suppression. We used superposed epoch analyses (SEA) to evaluate the mean moisture conditions for a 21-year window surrounding tree establishment dates. Before effective fire suppression (1809–1939), 24 of 42 trees with pith dates (62%) grew to 30-cm height during dry years (Palmer Drought Severity Index < -1), versus only 5 of 42 (12%) that established in wet years (PDSI > 1). Significantly more trees established during dry periods (negative PDSI values) than would be expected with the proportion of wet-to-dry years (x²= 10.738, df = 1, p-value = 0.001). Twenty of the complete sample of 74 trees with pith dates (27%) established during drought in the 1930s. We hypothesize that dry conditions limited plant productivity, which in turn decreased competition between grasses and tree seedlings and reduced rates of accumulation of fine fuels, enabling seedlings to grow tall enough to resist subsequent fires. We recommend SEA as a methodological approach to compare historical climate conditions with the timing of regeneration success in other regions of forest expansion.

E-commerce is an arguably new way of trading goods or services for monetary values through electronic means. It has increased in volume over the past years and it is not predicted to stop increasing in Sweden. The Swedish market holds a substantial amount of internet users who are in fact e-consumers. The European Union has taken a series of measures to harmonize the legislation regarding e-commerce in order to increase cross border e-commerce between the member states. The authors aimed to investigate the effect of the Swedish legislation on foreign companies’ establishment process on the Swedish e-commerce market. In order to achieve this, two in-depth interviews were conducted, one with a lawyer with considerable competence regarding e-commerce and the other one was in association with our case study on a French company that recently entered the Swedish e-commerce market. The research resulted in the notion that the Swedish legislation does differ from the European legal standards and that foreign ECCs have to adapt to the Swedish legislation. Another important finding is that European legislation is different between nations due to the variations in the interpretations of the same law text incorporated into the national legislations in the member states of the European Union. The resource based model of entry was also re-interpreted to facilitate the internationalization process of the companies.

The University of Piano was a private, liberal arts college with a campus in Piano, Texas and an extended campus in Frisco, Texas. The University was incorporated in 1964 under the original name of the University of Lebanon. Classes began in temporary space in downtown Dallas in 1964 and continued on its campuses in Piano and Frisco until the summer of 1976. The University of Piano was comprised of two separate schools within the University: the School of Developmental Education and the Frisco College of Arts and Sciences. This study explores the curricula of both schools and the students and faculty who participated in both programs. This study focuses on the establishment, development and final closing of a wholly privately supported university which accepted both traditional college students and students whose basic academic skills or neurological development prevented their acceptance into traditional college programs. It addresses the history of the University, the roles of its leaders, and the lasting effects of its programs.