This dissertation examines whether South Africa's interest deduction tax laws are compatible with selected aspects of their Double Taxation Treaties that are based on the 2017 OECD Model Tax Convention. This dissertation will outline and examine the innerworkings of three of South Africa's domestic interest deduction legislative provisions namely, sections 23N, 31 and 23M of the Income Tax Act. Thereafter, the relevant Non-Discrimination provisions of the 2017 OECD Model Tax Convention contained in Article 24 will be discussed. The exemptions to Article 24 will also be dealt with before addressing the impact of the recently added ‘Savings Clause'. The understandings gained from the above will then be used to test South Africa's interest deduction legislative provisions against the relevant Articles of the OECD Model Tax Convention. This dissertation concludes the following: section 23N does not constitute discrimination; section 31 necessarily does but falls within one of the exemptions to Article 24; and section 23M violates the non-discrimination provision contained in Article 24(4) and as such, is not compatible with any of South Africa's Doubled Taxation Treaties that contain the relevant Articles. This dissertation ends off with recommendations on how South Africa deals with the conflict, the best of which is to amend section 23M to include an arm's length requirement.

Goddess imagery in contemporary novels by Indian women. / A Thesis submitted to the Department of International Affairs in partial fulfillment of the requirements for the degree of Master of Arts. / Fall Semester, 2003. / November 7, 2003. / India, Goddess / Includes bibliographical references. / Kathleen Erndl, Professor Directing Thesis; Burton M. Atkins, Committee Member; J. Grant, Committee Member.

Globalization has been associated with the hegemony of traditional Western economic powers. However, the twenty-first century announced the emergence of new economic powers. The financial crisis crippling the West has not been as detrimental to these Southern economies and could introduce a new international balance of power. It also demonstrated that economic activities should serve humanity. While the BRICS club (Brazil, Russia, India, China, and South Africa) constitutes a plurilateral - because of its selectiveness - challenge and strength to multilateralist Western institutions, developing economies are attracting growing attention, especially Africa in the past decade. Similarly, Brazil's social and political conditions have been considerably ameliorating, thus distinguishing it from the other emerging powers. The South-South bridge between Africa and Brazil could then announce a new international economic and diplomatic order. A presentation of Brazil and Africa will lead to the description of the levels of governance interactions between the two regions and their economic exchanges. Finally, the socio-economic prospects of such relation and their consequences in the multilateral globalized world will be presented. I will then argue the possibility for the Brazil-Africa relationship, a mainly plurilateralist one, to initiate a new form of multilateralism, one uniting economic and social development. / A Thesis submitted to the Department of International Affairs in partial fulfillment of the requirements for the degree of Master of Science. / Summer Semester, 2012. / June 19, 2012. / Africa, Brazil, Economic Diplomacy, Multilateralism, Plurilateralism, South-South Cooperation / Includes bibliographical references. / Jim Cobbe, Professor Directing Thesis; Petra Doan, Committee Member; Alexander Aviña, Committee Member.

The Cold War ended with the fall of the Soviet Union in the early 1990s. Things were fine for a time, but in recent years tensions have begun to emerge between these two nations. Policy makers in both Washington and Moscow seem to be reverting to their old habits of a Cold War mentality, and some have even said that we are witnessing the beginnings of a Second Cold War. But Cold War is not a natural state. In the over one-hundred and fifty year history of relations between the United States and Russia, only forty of those years made up the Cold War. The majority of these years were characterized by peace, and there were even times when the two called each other allies. Now must be another of those times. The global threats of international terrorism, nuclear containment and proliferation, and plateauing energy supplies cannot be resolved by either the United States or Russia alone. Working for cross-purposes on these issues would lead to failure on both sides. However, due to the existing high tensions over American Anti-Ballistic Missile Diplomacy, NATO expansion into Eastern Europe, and Russia's invasion of Georgia, fruitful negotiations on these issues would be next to impossible at the present time. The solution must be a confidence building measure, but one as far from Eastern Europe and the Caucuses as possible; one excellent opportunity is in Japan. Near the end of World War II, the issue of Russian involvement in the war with Japan was one of the issues of contention which would lead to the Cold War. Because of America's role in Japan during the Cold War, Japan and the Soviet Union would never reach a peace agreement officially ending World War II. Since the end of the Cold War, low motivation and a minor border dispute have kept the two from reaching an official peace agreement. America's role in these negotiations will be to nudge the two towards peace, while at the same time signaling to Russia that the Cold War is officially over and that the United States is open to discussions on the true issues of contention. The United States needs Russia's help with its greatest challenges as it continues in the twenty-first century. The time to end the Second Cold War is now. / A Thesis submitted to the Department of International Affairs in partial fulfillment of the requirements for the degree of Master of Science. / Fall Semester, 2008. / September 23, 2008. / International Relations, International Affairs, American History, International History, Russia, Japan, Cold War, Second Cold War, War on Terrorism, Atomic Diplomacy, Anti-Ballistic Missile Diplomacy, Anti-Ballistic Missile, Missile Defense, Kurile Islands, Georgia, Chechnya, NATO, Caucasus / Includes bibliographical references. / Jonathan Grant, Professor Directing Thesis; Michael Creswell, Committee Member; Charles Upchurch, Committee Member.

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Includes bibliographical references.

Includes abstract. / Includes bibliographical references (leaves 72-75). / The timing of post-conflict elections is a critical element that requires careful consideration to minimize the risk of producing adverse results. Through examining the literature and studying Liberia's 1997 and 2005 elections, this work seeks to identify the best timing practices for post-contlict elections. The theoretical basis, which is inspired by the works of Roland Paris and Terrence Lyons, is that if the circumstances are to permit the long-term goal of democratization, then post-conflict elections should follow a protracted transition period prior to holding the election.

Foreign aid to Malawi has the ability to perpetuate the country's fifteen-year long hunger crisis. For millions of Malawians, chronic starvation is attributable to their inability to access food available on internationalised markets. Bilateral foreign aid to the Southern African state is aimed at stimulating development which, if successful, should also lift the country beyond threat of chronic, long-term malnourishment for the poorest of its citizens. Donor's, however, measure developmental aid's success along a narrow set of indicators - such as economic growth - dictating the direction of policy for recipient nations wishing to maintain the inflow of aid. For Malawi, this is all but inevitable as foreign aid accounts for 40% of government revenue. As a result of this dependency on external income, Malawi's government has targeted economic growth in order to maintain its aid support. Economic growth in Malawi has been fuelled by public spending and is unsustainable in the long term. The rapid growth was accompanied by high levels of inflation and the further entrenchment of a perennial trade accounts deficit, leaving the national currency weak. In addition, the majority of public spending reinforces the country's economic identity of an agricultural state, ensuring that 90% of Malawians who rely on agriculture for an income will remain poor due to the imbalance of trade. The indirect perpetuation of an agricultural economy, alongside unsustainable and unstable growth, has led to a situation where most Malawians cannot afford to buy food.

Since the late 1990s economic insecurity and political uncertainty have continued to worsen in Zimbabwe. Zimbabwe's economy plunged into deep crisis in the early 2000s owing to failed fiscal policies and the highly criticised 'Fast-track' land reform program. Election related violence between 2002 and 2013 resulted in a state of insecurity thereby leading to an exodus of Zimbabwean migrants. An unprecedented influx of Zimbabwean migrants to South Africa (SA) led to high levels of illegal migration and the clogging up of the asylum seeker management system in the early 2000s. In 2009, SA launched the Dispensation of Zimbabweans Project (DZP) in order to achieve four main objectives: to reduce pressure on the asylum management system, to curb the deportation of illegal Zimbabwean migrants, to regularise Zimbabweans who were residing in SA illegally and to provide amnesty to Zimbabweans who had obtained South African documents fraudulently. The DZP was considered a success and a successor permit, the Zimbabwe Special Dispensation Permit (ZSP), was launched in 2014 to allow former DZP applicants to extend their stay in South Africa. Using government publications, parliamentary debates, non-governmental organization (NGO) and media reports it was found that the DZP reduced pressure on the asylum seeker management system while deportation figures dropped significantly. It was also found that, less than 6% (250 000) of an estimated 1,5 million undocumented migrants were documented during the regularisation processes. The DZP and ZSP projects complemented South Africa's highly restrictive approach to migration management and jealous safeguarding of access to permanent residence and citizenship. The regularisation projects also enabled the South African government to show sympathy towards Zimbabweans who were forced to migrate to South Africa by recognising that they could not return home as long as the situation back home remained unchanged.