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:...

Loans Between Trusts

Yet more on s 7C of the Income Tax Act In essence, s 7C of the Income Tax Act subjects to an annual donations tax, effective as from 1 March 2017, an interest-free or low-interest loan to a resident trust. The effect of applying the 20% donations tax rate to the 8%...

The Special Voluntary Disclosure

Extend the deadline! A group of tax practitioners (me included) is lobbying the National Treasury, requesting the Minister of Finance to grant an extension to the SVDP. Complexity During the 2002/2003 forex and tax amnesty process there was one valuation date for the...