Thesis (Ph. D.)--University of Hong Kong, 2002. / Includes bibliographical references (leaves 217-223).

Thesis (Ph. D.)--Johns Hopkins University, 1992. / Includes bibliographical references (leaves 439-459).

Thesis (LL.M(Advanced)) - University of Queensland, 2000. / Includes bibliography.

Thesis (M.B.A.)--University of Hong Kong, 1996. / Includes bibliographical references (leaf [81-82]).

Thesis (Ph. D.)--University of California, San Diego, 2000. / Vita. Includes bibliographical references (leaves 136-142).

Thesis (Ph. D.)--University of Texas at Austin, 1991. / Vita. Includes bibliographical references (leaves 145-159).

Most immigrants relocate to the "land of opportunities" in search of greener pastures. Because of their desperate circumstances, they often work much harder than the average American to succeed. Strong social ties embedded in ethnic communities of immigrant populations have been considered vital assets for immigrant entrepreneurs (Yang et al. 2011, p. 639). However, little quantitative research has been done on the influence of biological kinship and altruism within the arena of ethnic entrepreneurs. It is well-documented that successful immigrant entrepreneurs and businesses can create jobs for others as well. Members of the same ethnic group often form communities in a host country. These communities live near one another, speaking the same language and honouring the same culture. These factors play an essential role in immigrant entrepreneurship and the creation of enclave businesses. Ethnic economies potentially provide a protected market for production of ethnic goods and an opportunity for greater business networks - including providing experience and apprenticeship to co-ethnic employees. In this study, the hypothesis is that small businesses founded and operated by immigrants are much more likely to hire immigrants, especially immigrants from a home country identical or similar to their own. The data collected by questionnaire was analysed using the Social Sciences Statistical Package (SPSS). Frequency distribution tables were used to analyse the research questions. To accept or reject the hypothesis, a statistical analysis was conducted. The formulated hypotheses were tested using inferential statistics chi-square. As far as immigrant entrepreneurs and their businesses are concerned, the descriptive study methodology used to test the hypothesis was successful in the sense that the results validated the idea that indeed immigrant small business owners are drawn towards other immigrants, preferably of their own ethnic or cultural background.

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

The objective of this thesis was to analyse the effect of the increasing popularity of global e-commerce on the South African legislative framework in respect of the taxation of non-resident enterprises, and to propose a possible solution for the taxation of e-commerce, taking into account previous theories. The methodology utilised comprised of a critical analysis of the legal rules relating to the taxation of a foreign entity's business profits by virtue of the application of the permanent establishment principle, its definition and evolution as a conceptual basis for taxation. Furthermore, an in depth evaluation of the various solutions that have already been proposed and, in some cases, implemented was undertaken. It was concluded that the application of the permanent establishment principle is wholly ineffective as a means to levy tax on the e-commerce business profits of a foreign entity as the principle relies too heavily upon a physical intermediary in the source state, whereas e-commerce transactions are conducted on the intangible trading platform of the Internet. In light of the numerous policy proposals advanced over the years, it was concluded that the most feasible and practical solution for the taxation of foreign e-commerce would be the imposition on a foreign entity in South Africa of a low withholding tax on the active business profits in excess of a pre-determined threshold. Key words: South African taxation; e-commerce; foreign business entity; permanent establishment; withholding tax