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The tax implications of tax concessions, compromises and assessed losses

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dc.contributor.advisor Mrs. A. Boshoff and Prof. K. Jordaan en_US
dc.contributor.author Myburgh, Andries Johannes
dc.date.accessioned 2012-09-07T09:31:00Z
dc.date.available 2012-09-07T09:31:00Z
dc.date.issued 2012-09-07
dc.date.submitted 2001
dc.identifier.uri http://hdl.handle.net/10210/7164
dc.description M.Comm. en_US
dc.description.abstract The objective of this study is to examine the preference share scheme devised in practice to acquire a company (with the assessed loss of the acquired company still intact) in terms of the procedures as provided for in section 311 of the Companies Act (Act 61 of 1973; hereafter referred to as the Companies Act). The study mainly aims at discussing and analysing the standard scheme, the preference share scheme and the future of the preference share scheme in light of the recent decision of the Supreme Court of Appeal in CIR v Datakor Engineering (Pty) Ltd 1998 CLR 574 (A) (hereafter referred to as the Datakor case) which has thrown the proverbial cat amongst the pigeons with reference to schemes of arrangements. In order to properly focus this study it is limited to an analysis of the provisions of section 20(1)(a)(ii) of the Income Tax Act (Act 58 of 1962) (hereafter referred to as the Act) with reference to the Datakor case, and the antiavoidance provisions contained in section 103(2) of the Act. en_US
dc.language.iso en en_US
dc.subject Tax compromises en_US
dc.subject Corporations - Taxation en_US
dc.title The tax implications of tax concessions, compromises and assessed losses en_US
dc.type Mini-Dissertation en_US

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