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...

Late objections and appeals

Issue 5 of Interpretation Note 15 On 21 December 2018, SARS issued an updated Interpretation Note 15 (Issue 5). This pertains to the exercise of a senior SARS official’s discretion to condone a late objection or appeal. The legal principles underlying the relevant...

Donations tax conundrums

Festive gifts It’s the festive season and ’tis the season for giving. Maybe it is coincidental that the topic of donations to political parties, high-profile persons and others features prominently in the press. Donations tax is levied by s 54 of the Income Tax Act,...