Donations tax implications of BEE transactions: more than meets the eye?

Abstract : The primary reason for companies entering into a Black Economic Empowerment (hereafter BEE) transaction is to achieve regulatory compliance. In a BEE transaction companies either issue new shares or sell existing shares, at a discount. The purpose of this study is to identify whether this discount element has donations tax implications. Donations tax is triggered by either actual or deemed donations. No actual donation takes place when new shares or existing are issued at a discount. The issue of new shares does not constitute property for purposes of section 54 of the South African Income Tax Act. The sale of existing shares at a discount in a BEE transaction lacks liberality or generosity. However, even if no actual donation takes place, a deemed donation can still take place in terms of section 58(1) of the Income Tax Act. A deemed donation takes place where property is disposed of for a consideration that is not adequate. The South African Revenue Service (SARS) have interpreted, that adequate consideration does not necessarily mean “fair market value”. SARS ruled in a Binding Private Ruling that specifically addressed the issue at hand, that the disposal of the shares (at a discount) comprised an adequate consideration, hence no donations tax arises. SARS unfortunately did not give a reason for their ruling. The issue remains contentious and unclear. The recommendation is made, in the interest of certainty, that a legislative amendment be introduced into section 56, which will exempt BEE transactions from donations tax

A framework for assessing the performance of pulsar search pipelines

In this paper, we present a framework for assessing the effect of non-stationary Gaussian noise and radio frequency interference (RFI) on the signal to noise ratio, the number of false positives detected per true positive and the sensitivity of standard pulsar search pipelines. The results highlight the necessity to develop algorithms that are able to identify and remove non-stationary variations from the data before RFI excision and searching is performed in order to limit false positive detections. The results also show that the spectrum whitening algorithms currently employed, severely affect the effciency of pulsar search pipelines by reducing their sensitivity to long period pulsars.IS

Assessment of the potential adoption of infield rainwater harvesting technique in the communal farming areas of the upper and middle Modder River Basin, South Africa

Published ArticleRiver basin is a geographical unit that defines an area where various users of the basin's water interact. In a river basin there are many water-related human interventions that modify the natural systems and impact on those who live downstream. Researchers from the Agricultural Research Council's Institute for Soil, Climate and Water (ISCW) have developed an infield rainwater harvesting (IRWH) technique for small-scale farmers in the Modder River basin. This technique increased crop yield significantly compared to conventional practices. Since the start of its dissemination by the ISCW programme, adoption at a homestead level grew from six to more than 950 households. The suitable land for the IRWH in the study area is estimated to be 80 667 hectares, of which approximately 14 500 hectares are in the communal farming area. If all the suitable areas were to be put under IRWH practice, a decrease in the runoff could be expected, with consequences on downstream water users. A field survey conducted using a participatory methodology on a sample of 21 villages selected randomly, revealed that there are strong positive motivators, such as increase in crop yield and more food available for the household which explain the rapid expansion of IRWH in homestead application. However, some very strong demotivators were identified, such as high levels of poverty, limited family labour for the preparation of the plots, lack of tools, and the lack of fences around community gardens which could lead to theft and damage by animals. It appears that the demotivators identified are strong enough to prevent a significant expansion of the IRWH technique beyond homestead scale. Hence the expected impact on water availability for downstream users is expected to be minimal

Sensory integration intervention and the development of the premature infant: A controlled trial

Background. Premature infants are at risk of sensory processing difficulties and developmental delays due to an immature central nervous system and possible episodes of medical instability, discomfort, pain and stress during the first weeks or months after birth.Objective. To investigate the effect of Ayres Sensory Integration (ASI) on the development of premature infants in the first 12 months of life.Methods. A pre-/post-test experimental design was used to randomly divide 24 premature infants from a low socioeconomic setting in Bloemfontein, South Africa, into experimental and control groups after being matched by corrected age and gender. Developmental status was determined with the Bayley III Scales of Infant and Toddler Development, the Test of Sensory Functions in Infants and the Infant/ Toddler Sensory Profile. The experimental group received 10 weeks of ASI intervention.Results. ASI intervention had a positive effect on the sensory processing and development of premature infants, especially in terms of cognitive, language and motor development.Conclusions. ASI intervention at an early age enhances the developmental progress of premature infants

A deep gold mine metagenome as a source of novel esterases

New sources of enzymes for biotechnological applications are continually being sought for. While diverse microbial ecosysyems have been demonstrated in the deep subsurfaces, deep mines provide easy access to these specialist communities. Therefore, the aim of this study was to assess a deep mine biofilm as a source of novel esterase enzymes. Biofilm was collected from the Beatrix Mine in South Africa, at a depth of 808 m. Assessment of the diversity revealed a group of previously uncultured bacteria and archaea. A metagenome library was screened for esterolytic activity, producing two esterolytic clones: a phospholipase patatin protein and an isochorismatase family protein. The isochorismatase family protein contained the catalytic Asp and Cys but not the Arg, which is considered as important for catalysis. The patatin showed 55% similarity to its closest relative; the patatin family protein from Plesiocystis pacifica. The expressed patatin displayed a preference for the C6 ester and was maximally active at pH 8 and 30°C. This study reported that screening of a relatively small metagenome library from the deep mine biofilm provided two esterolytic clones, which differed from their known counterparts. This indicates that the deep mine ecosystems contain an untapped resource of novel and potentially useful enzymes which may have applications in chemical syntheses.Key words: Metagenome library, functional screening, lipolytic activity, patatin, isochorismatas

Influence of feeding systems on selected beef quality and sensory attributes

Feeding systems and other factors associated with processing influence meat quality, and therefore sensory attributes. This study was conducted to assess the meat quality attributes of young grain-fed and older grass-fed steers that mostly affect consumer acceptability of beef. Eighty Bonsmara steers consisting of 20 each of A-age (0-tooth) grain-fed (AC) and grain-fed supplemented with zilpaterol (AZ), 20 each of grass-fed AB (1-2 teeth) and B-age (3 - 6 teeth) animals were used. This combination represented the typical feeding systems of South Africa and other countries using similar classification systems, therefore describes the typical feeding systems of the South African beef industry. The longissimus lumborum (LL), semitendinosus (ST), and biceps femoris (BF) muscles were tested for colour, moisture properties, lipid oxidation and sensory attributes. It was found that diet in combination with animal age influenced meat colour. Muscles of the older grass-fed steers were generally darker and duller (darker red) compared to muscles of young grain-fed animals. Moisture loss was consistently higher in zilpaterol supplemented meat samples compared to the feedlot controls, while muscles of the grass-fed animals had lower moisture loss. A sensory panel clearly distinguished between cuts of grain-fed (AZ and AC) and grass-fed carcasses (AB and B) on the grounds of flavour characteristic. The AB and B cuts scored higher for grassy, animal-like and rancid flavour overtones and lower for roasted flavour and sourness than AZ and AC grain-fed cuts. This indicated that typical flavours related to diet define expected eating quality. Keywords: age, grain, grass, meat quality, zilpatero

Sosio-kulturele faktore in die studie en prestasie van sekere swart studente aan die Universiteit van Suid-Afrika : 'n verkennende kontekstuele ondersoek

Afrikaans textDie doel van hierdie ondersoek is om sosio-kulturele kenmerke van sekere swart studente aan die Universiteit van Suid-Afrika weer te gee en te bepaal of, op welke wyse, en watter, sosio-kulturele faktore 'n invloed op hul _studie en akademiese prestasie het. Dit is gedoen deur 'n kontekstuele, individualisties-holistiese en biografiese benadering toe te pas op gevallestudies waarvan die besonderhede deur diepte-onderhoude verkry is. Deur middel van die gevallestudies word 'n algemene oorsig van die betrokke studente se kinderjar.e en volwasse lewe buite universiteitsverband gegee. Die volwasse lewe word beskryf aan die hand van gemeenskaplike aktiwiteitsvelde waaraan die individue deelneem. Die universiteit word ook as 'n aktiwiteitsveld beskou en in terme van die betrokke studente se deelname daaraan volledig beskryf met inagneming van die verband daarvan met ander aktiwiteitsvelde. Vervolgens is uit die beskrywing van die kinderjare, die volwasse lewe buite universiteitsverband en die veld van die universiteit faktore geidentifiseer wat 'n invloed blyk te he op die studie en prestasie van die studente in die ondersoekgroep. Die gevolgtrekkinge is dat daar verskeie sosiokulturele en 'n aantal ander faktore is wat studie. en akademiese prestasie beinvloed en dat daar variasie is in die invloed van sodanige faktore by verskillende individue.The aim of this investigation is to give an exposition of the socio-cultural characteristics of certain black students at the University of South Africa and to determine wheth~r, in what way, and which, socio-cultural factors influence their studies and academic performance. The study entailed the application of a contextual, individualisticholistic and biographical approach to case studies, the details of which were obtained through in-depth interviews. A general overview of the childhood of the students concerned and of their adulthood outside the context of the university, is provided by means of the case studies. Adulthood is described in terms of common fields of activity in which the individuals participate. The university is also regarded as a field of activity and is described fully in terms of the participation of the students involved, with due regard for relations between the university and other fields of activity. From the descriptions of childhood, adulthood outside the context of the university, and also of the field of activity of the university, factors are identified which appear to influence the studies and performance of the students with whom case studies were conducted. Conclusions reached reveal diverse socio-cultural as well as a number of other factors that influence study and academic performance, as well as a variation in the influence of such factors on different individuals.Anthropology and ArchaeologyD. Litt. et PHil. (Antropologie

Up-scaling of rainwater harvesting for crop production in the communal lands of the Modder River basin in South Africa: comparing upstream and downstream scenarios

Published ArticleThe study area is the Upper and Middle Modder River basin situated in a semi-arid area of central South Africa. This is an important catchment because of the relatively large nearby towns of Bloemfontein, Botshabelo and Thaba Nchu. Crop production in the basin using conventional production techniques is currently not suitable due to marginal and erratic rainfall, and high evaporative demand, as well as low precipitation use efficiency on the clay and duplex soils caused by large runoff and evaporation losses. A labour-intensive in-field rain-water harvesting (IRWH) technique for crop production recently introduced into a part of the basin occupied by communal farmers has been shown to increase maize and sunflower yields by 30 to 50% compared to conventional tillage, making crop production utilising this technique a feasible proposition for these farmers. The area of land suitable for the IRWH in the basin is estimated to be 80 667 ha, of which 15 000 ha is located in the communal land. The two catchment management options compared in this paper are: • Allowing the 80 667 ha to remain under grassland and utilising the runoff downstream for irrigating maize • Utilising the 80 667 ha for maize production in the basin using the IRWH technique. Results showed that the expected maize production from the options shown above were 23 040t and 137 134t respectively. The large unproductive water losses during storage and conveyance to downstream use points are probably the main reason for this large difference in production. An economic analysis, which enabled the grazing benefit to be included in the first option, shows that the gross margin of this option, expressed as R/m3 of rain water utilized, could be expected to be between 0.0234 to 0.0254 under current conditions, of which irrigation contributed about 25% or less. The comparable value for the IRWH option was 0.0354. The second option is clearly shown to be the most preferable, with high socio-economic benefits for the communal farmers who are currently struggling to achieve sustainable livelihoods