Discretionary Trusts

Changing the beneficiaries Existing trust structures being revisited Given the advent of s 7C of the Income Tax Act, which subjects to annual donations tax an interest-free or soft-interest credit loan claim by a funder (whether a settler, beneficiary or connected...

Taxpayer Bill of Rights mooted

Davis Tax Committee Recommendations The Davis Tax Committee has just released a Tax Administration Report, dated September 2017 (see the Monthly Listing), which, amongst other things, addresses the need for a Taxpayer Bill of Rights (TBOR). The TBOR should be...

The Post-SVDP Era

Regularization of foreign assets SVDP Deadline Passed The Special Voluntary Disclosure Program (SVDP) deadline has now passed, on 31 August 2017. Taxpayers holding foreign assets in breach of either the exchange control or tax laws and regulations nevertheless enjoy...

Global Tax Village

International tax noose tightens ‘Global village’, according to Wikipedia, is a term relating to the constant presence between one another due to the use of telecommunica­tions. The term is credited to Canadian-born Marshall McLuhan. In his books The Gutenberg Galaxy:...

Donations tax exemption and the VDP/SVDP

Section 56(1)(g) of the Income Tax Act Donation of foreign assets In the course of regularizing their offshore tax affairs under the normal Voluntary Disclosure Programme or the Special Voluntary Disclosure Programme, many taxpayers need, amongst other things, to...