481 |
Die boedelbelastingimplikasies van die aanwending van opeenvolgende beperkte regte / deur Gert Petrus Schlebusch AlbertseAlbertse, Gert Petrus Schlebusch January 2003 (has links)
The bequest of a usufruct to one or more interim usufructuaries for a limited period
after the decease of the first usufructuary is often utilised by estate planners to
reduce the value of the ceasing limited interest and thus to effect a saving in respect
of estate duty.
The saving in respect of estate duty is effected due to the fact that
- the value of the ceasing limited interest in the estate of the first
usufructuary is calculated only over the duration of the period during
which the interim usufructuary is entitled to the limited interest and not
also over the life expectancy of the ultimate beneficiary, and
- that, on the cessation of the interim usufruct due to the efflux of time.
no estate duty is payable.
The very first reference to this method appeared in an article published in The
Taxpayer during 1965. Other authors like Meyerowitz, Silke and Stein and Davis,
Beneke and Jooste also referred to this method without analysing it or
investigating the legality thereof. All the aforementioned authors relied to a certain
extent for their views on a judgment of acting judge Warner in Bassett v
Commissioner for Inland Revenue (1 961 4 SA 769 (D)).
This dissertation is therefore aimed at investigating the legality of the method and to
focus on a few practical aspects regarding the application thereof as an estate
planning instrument.
An analysis of the wording of the charging clause (section II (a )(1) of the Estate Duty
Act and the valuation clause (section 5(1) of the act) has led to the belief that, in
considering the validity of the method, it is extremely important to bear in mind the
principles applicable to the vesting of testamentary rights.
In terms of the valuation clause of the Estate Duty Ad the value of a ceasing limited
interest for estate duty purposes is determined by capitalising the annual value of
the right of enjoyment of the properly in which the deceased held any such limited
interest to the extent to which the person who, upon the cessation of the said
interest of the deceased in consequence of the death of the deceased, becomes
entitled to any right of enjoyment of such properly.
In terms of the charging clause "the person to whom any advantage accrues by the
death of the deceased" is liable for the payment of estate duty in respect of the
cessation of a limited right.
In order to calculate the value of a ceasing limited interest and to determine the
liability for payment of estate duty in respect thereof it is necessary to determine
(a) the extent to which a successor in title of a deceased in consequence of the
death of the deceased has become entitled to any right of enjoyment, and
(b) to which person any advantage has accrued by the death of the deceased.
After analysing the wording of section 5(1)(b) and section 11(a)(1) the writer has
come to the following conclusions:
(a) In the case of an interim usufruct the right of enjoyment of the first
usufructury has to be capitalised only over the period of currency of the
interim usufruct and not also over the life expectancy of the owner of the
nuda proprietas.
(b) Subsection 5(l)(b) does not make provision for the valuation of an interim
usufruct at the termination them due to the efflux of time.
(c) Upon the decease of the first usufructuary an advantage as contemplated in
section 11(a)(1) accrues to the interim usufructury but not to the owner of
the nuda proprietas.
(d) On the cessation of an interim usufruct due to the efflux of time there is no
person to whom any advantage accrues by the death of a deceased as
contemplated in subsection 11 (a)(1), and consequently the owner of the nuda
proprietas does not at that stage incur any liability for estate duty.
In view of the aforegoing considerations the writer has come to the conclusion that
the utilisation of this method does not constitute a contravention the provisions of the
Estate Duty Ad. The artificiality of the valuation method prescribed in terms of
subsection 5(1)(b) lends itself to reducing the value of a limited interest by
interposing a successor for a short period between the deceased and the ultimate
beneficiary.
It follows therefore that the utilisation of this method does not constitute tax evasion.
Where the main consideration for the appointment of an intermediary usufructuary is
not so much the possible benefit that may acme to the intermediary as the
limitation of estate duty, the application of the method may constitute an avoidance
of estate duty. The Estate Duty Act, however, does not contain any general anti-avoidance
provision similar to section 103 of the lncome Tax Act.
In utilising this method estate planners should therefore bear in mind the possibility
that the fiscus may sooner or later introduce an amendment to the Estate Duty Act
to close this loophole. / Thesis (LL.M. (Estate Law))--North-West University, Potchefstroom Campus, 2004.
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482 |
Optimising the operation of underground mine refrigeration plants and ventilation fans for minimum electricity cost / Christopher SwartSwart, Christopher January 2003 (has links)
This study describes the development and use of a mathematical model that will enable mine operators to
minimise the costs of electricity consumed by the ventilation and refrigeration systems used for
environmental control in deep mines.
This model was calibrated and tested by using actual data from a gold mine near Welkom in South
Africa. In a first simulation, the mine's current practice of controlling conditions to a wet bulb
temperature (Twb) of 25S°C, was optimised. The model demonstrated that this environmental condition
could be sustained at lower electricity consumption. In so doing, the mine realised a saving of 30 000
kWh per day. The energy saving and load management led to a cost saving of R 1.5 million per year.
However, a better indicator of environmental conditions is the Air Cooling Power index, (ACP).
Research has shown that for hard physical work in hot conditions workers need an ACP of 300 w/m2. It
was found that the case study mine actually supplied their workplace with a cooling capacity of 422
w/m2. The new model optimised the refrigeration and ventilation systems in such a manner that the
workers were supplied with exactly 300 w/m2, no more and no less. It was found that by doing this, an
electricity saving of 57 600 kWh per day could be realised when compared with the current mine
practices. The energy saving and load management led to a potential cost saving of R 2.55 million per
year. (Certain capital costs, such as for variable speed drives may have to be incurred to realise these
savings.)
The new model could be further extended to take advantage of the new Real Time Price offerings from
Eskom It will be able to identify an operating point for the refrigeration and ventilation systems to
supply 300 w/m2 for the workers, in real time, at the lowest electricity cost. / Thesis (Ph.D. (Mechanical Engineering))--North-West University, Potchefstroom Campus, 2004.
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483 |
Žmogaus gelbėjimo sąlygų, įvykus nelaimingiems atsitikimams žemės ūkio darbuose, tyrimas / Nelaimingas atsitikimas darbe, žemės ūkis, pasirengimas gelbėti, mirtinai traumuotasKuliešius, Edgaras 09 June 2009 (has links)
58 teksto puslapiai, 15 lentelių, 9 paveikslų, 52 literatūros šaltiniai, 5 priedai. Darbo tikslas – išanalizuoti žmonių gelbėjimo, įvykus nelaimingam atsitikimui, aktualumą, atskleisti problemos aktualumą žemės ūkio gamyboje, ištirti žemės ūkio darbuotojų pasirengimą gelbėti mirtinai traumuotą žmogų ir pasiūlyti priemones šiam pasirengimui gerinti. Nustatyta, kad 60-70 proc. iš visų nelaimingų atsitikimų (NA) įvyksta dėl neteisingų dirbančiojo veiksmų. Išnagrinėtos žmogaus psichofizinės savybės, dėl jų susiformuojantys veiksniai, kurie tampa NA priežastimi. Nustatytos kai kurios priemonės, mažinančios šių priežasčių pasireiškimą. Aukštesnis saugumo lygmuo gali būti pasiektas diegiant naujų, sudėtingesnių pažangios technologijos pavojų kontrolę, tam kad aukšto lygio saugumas panaikintų pažangios technologijos pavojus bei tos priemonės butų įgyvendintos. Lietuvoje žemės ūkis pagal įvykusių NA darbe skaičių yra šeštoje vietoje iš penkiolikos tarp visų ekonominės veiklos rūšių. Atlikus sociologinį tyrimą, kuriame dalyvavo 241 žemės ūkio darbuotojai iš įvairių Lietuvos regionų, buvo nustatyta, kad ūkininkai du kartus dažniau nei samdomi darbuotojai sugebėtų gaivinti staiga mirusį žmogų. Atlikus eksperimentinius tyrimus, paaiškėjo, kad pirmosios pagalbos mokymo efektyvumas priklauso nuo mokymo metodų. / Thesis of Master: 58 pages, 15 tables, 9 pictures, 52 sources of literature, 5 appendixes. Research goal – analyse people life saving urgency during accident, discover problem importance in agriculture industry, examine agriculturists preparation for life saving to man who is deadly traumatized and propose a new measures to improve this preparation. It is established, that 60-70 proc. of all accidents are occurred because of wrong worker actions. Person‘s psychophysical characteristics, factors caused by these characteristics that become the reasons of accidents werw investigated. It was foreseen some means that decrease display of these reasons. A higher level of safety may be achieved through control of the new, more complicated risks of advanced technology if high-level safety complicated risks of advanced technology if high-level safety engineering has been implemented. In Lithuania agriculture industry is the sixth from the top in the list of fifteen kinds of economical activity in means of number of work accidents. After sociological investigation among 241 agriculture workers from different regions of Lithuania, we have discovered twice more farmers, comparing with hired labour men, know, how to act, when work accident has occured. The expermental investigation results proved dependence of right training methods to higher effectiveness of first aid training.
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Contributing to energy efficiency through a user-centered smart homeDominici, Michele 03 June 2013 (has links) (PDF)
Smart homes are residences equipped with information and communication technologies that anticipate and respond to the needs of the occupants. Despite the numerous research and industrial efforts, today only few expensive smart homes have been built and sold. The reason behind this slow uptake is the technology-driven approach characterizing existing solutions. The doctoral Thesis aims at demonstrating that a smart home can provide functionalities designed with a user-centered approach, taking into account ergonomic considerations about domestic activity and human cognition. This is achieved in collaboration with cognitive ergonomists, which help "minding the gap" between human context and machine-understandable context. Using off-the-shelf and lightweight instrumentation (also minimizing privacy concerns), extending existing context modeling, reasoning and management tools and following the Ubiquitous Computing principles, the doctoral work led to the following achievements: (i) the inter-disciplinary design of suitable functionalities, in collaboration with cognitive ergonomists; (ii) the design of a context-aware system that captures and reasons about uncertain contextual information in a distributed fashion; (ii) the realization of a working prototype that demonstrates the provision of energy-saving and comfort-preserving functionalities.
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E-Grocery in Digital Age : ICA MAXI in GävleKuang, Peiying, Ali, Mahmood January 2014 (has links)
Aim: The purpose of this study is to identify factors that can attract customers to buy online and help the grocers to improve their online grocery services to retain and obtain customers. Design/Methodology/Approach: A qualitative method was used, based on triangulation methodology including observation and interviews of manager and employees. Quantitative data was collected by handing out questionnaire to 204 potential customers and 30 existing customers. Findings: The study shows that product and service quality, time saving and convenience, web page layout, customers’ trust in grocers (service providers), store image and advertising are the important factors that customers consider when they decide to use online grocer service. E- grocers also need to consider these factors when they start online grocery service. Suggestions for Future Research: An extensive study with large population sample and co- operation from other companies can help to generalize the results. Future studies can be extended to include drive-in and shared reception box service method, and consider the cost for the customers in e-grocery sector.
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486 |
Die boedelbelastingimplikasies van die aanwending van opeenvolgende beperkte regte / deur Gert Petrus Schlebusch AlbertseAlbertse, Gert Petrus Schlebusch January 2003 (has links)
The bequest of a usufruct to one or more interim usufructuaries for a limited period
after the decease of the first usufructuary is often utilised by estate planners to
reduce the value of the ceasing limited interest and thus to effect a saving in respect
of estate duty.
The saving in respect of estate duty is effected due to the fact that
- the value of the ceasing limited interest in the estate of the first
usufructuary is calculated only over the duration of the period during
which the interim usufructuary is entitled to the limited interest and not
also over the life expectancy of the ultimate beneficiary, and
- that, on the cessation of the interim usufruct due to the efflux of time.
no estate duty is payable.
The very first reference to this method appeared in an article published in The
Taxpayer during 1965. Other authors like Meyerowitz, Silke and Stein and Davis,
Beneke and Jooste also referred to this method without analysing it or
investigating the legality thereof. All the aforementioned authors relied to a certain
extent for their views on a judgment of acting judge Warner in Bassett v
Commissioner for Inland Revenue (1 961 4 SA 769 (D)).
This dissertation is therefore aimed at investigating the legality of the method and to
focus on a few practical aspects regarding the application thereof as an estate
planning instrument.
An analysis of the wording of the charging clause (section II (a )(1) of the Estate Duty
Act and the valuation clause (section 5(1) of the act) has led to the belief that, in
considering the validity of the method, it is extremely important to bear in mind the
principles applicable to the vesting of testamentary rights.
In terms of the valuation clause of the Estate Duty Ad the value of a ceasing limited
interest for estate duty purposes is determined by capitalising the annual value of
the right of enjoyment of the properly in which the deceased held any such limited
interest to the extent to which the person who, upon the cessation of the said
interest of the deceased in consequence of the death of the deceased, becomes
entitled to any right of enjoyment of such properly.
In terms of the charging clause "the person to whom any advantage accrues by the
death of the deceased" is liable for the payment of estate duty in respect of the
cessation of a limited right.
In order to calculate the value of a ceasing limited interest and to determine the
liability for payment of estate duty in respect thereof it is necessary to determine
(a) the extent to which a successor in title of a deceased in consequence of the
death of the deceased has become entitled to any right of enjoyment, and
(b) to which person any advantage has accrued by the death of the deceased.
After analysing the wording of section 5(1)(b) and section 11(a)(1) the writer has
come to the following conclusions:
(a) In the case of an interim usufruct the right of enjoyment of the first
usufructury has to be capitalised only over the period of currency of the
interim usufruct and not also over the life expectancy of the owner of the
nuda proprietas.
(b) Subsection 5(l)(b) does not make provision for the valuation of an interim
usufruct at the termination them due to the efflux of time.
(c) Upon the decease of the first usufructuary an advantage as contemplated in
section 11(a)(1) accrues to the interim usufructury but not to the owner of
the nuda proprietas.
(d) On the cessation of an interim usufruct due to the efflux of time there is no
person to whom any advantage accrues by the death of a deceased as
contemplated in subsection 11 (a)(1), and consequently the owner of the nuda
proprietas does not at that stage incur any liability for estate duty.
In view of the aforegoing considerations the writer has come to the conclusion that
the utilisation of this method does not constitute a contravention the provisions of the
Estate Duty Ad. The artificiality of the valuation method prescribed in terms of
subsection 5(1)(b) lends itself to reducing the value of a limited interest by
interposing a successor for a short period between the deceased and the ultimate
beneficiary.
It follows therefore that the utilisation of this method does not constitute tax evasion.
Where the main consideration for the appointment of an intermediary usufructuary is
not so much the possible benefit that may acme to the intermediary as the
limitation of estate duty, the application of the method may constitute an avoidance
of estate duty. The Estate Duty Act, however, does not contain any general anti-avoidance
provision similar to section 103 of the lncome Tax Act.
In utilising this method estate planners should therefore bear in mind the possibility
that the fiscus may sooner or later introduce an amendment to the Estate Duty Act
to close this loophole. / Thesis (LL.M. (Estate Law))--North-West University, Potchefstroom Campus, 2004.
|
487 |
Optimising the operation of underground mine refrigeration plants and ventilation fans for minimum electricity cost / Christopher SwartSwart, Christopher January 2003 (has links)
This study describes the development and use of a mathematical model that will enable mine operators to
minimise the costs of electricity consumed by the ventilation and refrigeration systems used for
environmental control in deep mines.
This model was calibrated and tested by using actual data from a gold mine near Welkom in South
Africa. In a first simulation, the mine's current practice of controlling conditions to a wet bulb
temperature (Twb) of 25S°C, was optimised. The model demonstrated that this environmental condition
could be sustained at lower electricity consumption. In so doing, the mine realised a saving of 30 000
kWh per day. The energy saving and load management led to a cost saving of R 1.5 million per year.
However, a better indicator of environmental conditions is the Air Cooling Power index, (ACP).
Research has shown that for hard physical work in hot conditions workers need an ACP of 300 w/m2. It
was found that the case study mine actually supplied their workplace with a cooling capacity of 422
w/m2. The new model optimised the refrigeration and ventilation systems in such a manner that the
workers were supplied with exactly 300 w/m2, no more and no less. It was found that by doing this, an
electricity saving of 57 600 kWh per day could be realised when compared with the current mine
practices. The energy saving and load management led to a potential cost saving of R 2.55 million per
year. (Certain capital costs, such as for variable speed drives may have to be incurred to realise these
savings.)
The new model could be further extended to take advantage of the new Real Time Price offerings from
Eskom It will be able to identify an operating point for the refrigeration and ventilation systems to
supply 300 w/m2 for the workers, in real time, at the lowest electricity cost. / Thesis (Ph.D. (Mechanical Engineering))--North-West University, Potchefstroom Campus, 2004.
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488 |
En byggnads energibehov : En studie om energieffektivisering av en befintlig byggnad i södra SverigeÅström Ylivainio, Frida January 2014 (has links)
The purpose of the study was to investigate the use and losses of energy in an existing older building. Another purpose was also to look through various options for heating systems with renewable energy in the building. The aim was to reduce the use and losses of energy. The first step was to study the related electricity bills of the building and also perform measurements and calculations of the building envelope and ventilation. The next step was to find out the possible actions for energy saving by performing measurements and calculations. To calculate the loss of energy a u-value was used, which describes a materials ability to conduct heat. The results of the energy calculations show what is reasonable to do in the building considering the energy savings versus economy. The study shows that it is important to first analyze and adjust the building envelope and ventilation before a new heating system is installed. That is to reduce the risk of an over-sizing of the heating system. It is not optimal to correct the entire building at energy efficiency because it is not economically feasible. All necessary actions of energy saving should be taken as a package where the most profitable should be picked out and executed. An older building is often of great value and therefore its appearance should be safeguarded at energy efficiency.
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Portfolio-based segmentation and consumer behavior : empirical evidence and methodological issuesGunnarsson, Jonas January 1999 (has links)
Recent work in the area of retail financial services marketing almost invariably cite the deregulation of national and international financial markets as a major reason as to why financial institutions have a need for better knowledge of their customers' behaviors and needs. Among the most sought-after information are better ways to segment and target the market, that is, how do groups of households behave with regards to their savings and investments, why do they behave in certain ways, how can we reach them and how do they respond to marketing activities? In this thesis we will attempt to shed light on some salient aspects of the first two of these four questions.Three of the papers in this volume are based on the segmentation of the market for retail financial services based on different financial strategies, as expressed in households' portfolio choices. In the first two papers, such behavioral segmentation is carried out on data from samples of Swedish and Dutch households. Issues concerning the stability of segmentation over time are also highlighted. The third paper is also focused on the concept of heterogeneity, but this time as expressed by different agents within the individual household, the question being whether the marketing researcher needs to collect data from both spouses in family households. In the fourth paper behavioral segments are used as domains to examine differences in human intertemporal discounting. / Diss. Stockholm : Handelshögsk.
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Money: a personal and private currencyWilson, Valerie Ann St. Clair January 1996 (has links)
This thesis confronts the ‘taken-for-granted’ nature of money. It explores the word ‘money’ itself, contrasting the way it is used/defined in the economics discourse with the way it has been approached in the psychological discourse. The thesis crosses disciplinary boundaries in an attempt to come closer to the everyday, personal experience of money. It unwraps the childhood history of money, showing how adult money attitudes emerge from unconscious predispositions and childhood experience. It demonstrates the importance of ‘control’ as a variable and the lifelong balancing act which takes place between spending and saving. Today, the form of money is in the process of change. It has undergone significant changes before: the nineteenth century adoption of paper money upset the bullionists as much as plastic or virtual money can unsettle traditionalists at the end of the twentieth century. Attitudes to the underlying substance 'money' remain relevant, whatever physical form the currency takes. Thus, gold and silver coins, the treasure of childhood pirate stories, may retain mental currency long after their demise as physical currency. Indeed, the more money becomes abstracted from something tangible, the more it is necessary to understand the primal nature of the underpinning attitudes that are affected.
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