Soft loans to nonresident trusts revisited

And more on s 7C of the Income Tax Act In 168 TSH 2017, I examined the interaction between the various sections of the Income Tax Act pertaining to resident funders of nonresident trusts. It is time to revisit this topic. Attribution rules (s 7(8))Section 7(8)...

Emigration and retirement fund access

In my previous article ‘Foreign employment income amendments’ (192 tsh 2019), I focused on the tax tests allowing one to achieve nonresident status. The further issue arises of the ability of an emigrant to access his or her retirement funds, and the tax treatment of...

State-capture beneficiaries and tax

An Al Capone strategy better than problematical prosecution In 189 TSH 2018 I canvassed aspects of donations tax relevant to ‘state capture’. Now it is time to look at its income tax implications. SARS’s mandate (updated 27 February 2019) is to ensure tax collection...

Foreign employment income amendments

Myths abound ‘Financial emigration’ Amidst the panic created by the amendments to s 10(l)(o)(ii) of the Income Tax Act, which, with effect as from 1 March 2020, will subject to tax in the RSA foreign employment income in excess of R1 million earned by RSA taxpayers...

Section 7C revisited

Dynamic tax environment can create opportunities Sometimes amendments to the tax legislation, albeit unwittingly, can have favourable results for a taxpayer. As the saying by the inventor, Alexander Graham Bell, goes, ‘when one door closes, another opens’. An example...