Cryptocurrencies: Do they qualify as "gross income"?

This article argues that, for purposes of the Income Tax Act 58 of 1962, Bitcoin and cryptocurrencies operating in a like manner are incorporeal property with a comparable value in real currency. The fundamental basis for the advancement of the hypothesis that such cryptocurrencies give rise to protectable proprietary rights are: (i) the rights exist digitally in cyberspace; (ii) the rights have value to their users; (iii) the rights are capable of being owned as cyberproperty; (iv) the rights can be transferred electronically by a possessor of a unique public-private cryptography protected keypair, and (v) the rights can be proved by entries in a digital ledger that records the historical chain of ownership transfers. This article argues further that the average, fair market value of the cryptocurrency in South African Rands on the date of its receipt or accrual as a revenue asset must be included in a taxpayer’s gross income. It is further argued that this value ought to be the average price of the cryptocurrency determined with reference to at least two pricing indices commonly used or accepted in the marketplace

Warrantless search and seizure by SARS: A constitutional invasion of taxpayers' privacy? - Part one

Sec. 63 of the Tax Administration Act 28 of 2011 (TAA) grants unto the South African Revenue Service (SARS) officials access to taxpayers’ private and confidential information through, first, searching a taxpayer’s person and premises without a warrant and, secondly, permitting the seizure of taxpayers’ possessions and communications. Part One of this article argues that the TAA is a “law of general application”, as envisaged by the so-called “limitation clause” contained in sec. 36(1) of the Constitution, 1996 and that – in terms of the threshold stage of analysis prescribed by this provision – the exercise of the powers conferred by secs. 63(1) and (4) limits a taxpayer’s constitutional right to privacy as entrenched in sec. 14 of the Constitution. Part Two of this article (to be published in JJS 2021(2)) hypothesises that, although the search and seizure powers in secs. 63(1) and (4) of the TAA are not models of drafting with absolute clarity, they ought – in terms of the second stage of enquiry that is triggered by the findings in Part One – nevertheless to pass muster under sec. 36(1) of the Constitution. This is because of the justifiability of the limitation imposed on the right to privacy by these provisions

Normal, Abby Normal, Prefix Normal

A prefix normal word is a binary word with the property that no substring has more 1s than the prefix of the same length. This class of words is important in the context of binary jumbled pattern matching. In this paper we present results about the number $pnw(n)$ of prefix normal words of length $n$, showing that $pnw(n) =\Omega\left(2^{n - c\sqrt{n\ln n}}\right)$ for some $c$ and $pnw(n) = O \left(\frac{2^n (\ln n)^2}{n}\right)$. We introduce efficient algorithms for testing the prefix normal property and a "mechanical algorithm" for computing prefix normal forms. We also include games which can be played with prefix normal words. In these games Alice wishes to stay normal but Bob wants to drive her "abnormal" -- we discuss which parameter settings allow Alice to succeed.Comment: Accepted at FUN '1

Systems, methods and computer program products for prediction of defect-related failures in integrated circuits

Systems, methods and computer program products for predicting defect-related failures in integrated circuits produced by an integrated circuit fabrication process identify objects in a circuit layout for the integrated circuit design, each object having a location in the circuit layout and a reliability connectivity in the integrated circuit design. Sample object defects are generated for the identified objects, each sample object defect representing a defect produced in an object by the integrated circuit fabrication process and having a defect magnitude associated therewith. An accelerated life defect influence model is identified for each sample object defect, relating the lifetime of an object to the defect magnitude of a defect in the object. Sample object lifetimes are generated from the defect magnitudes associated with the sample object defects according to the corresponding identified accelerated life defect influence models. A prediction of the reliability of integrated circuits is generated from the sample object lifetimes according to the reliability connectivity of the associated objects in the integrated circuit design. Preferably, the accelerated life defect influence models include log-linear regression models, which may include deterministic object lifetime functions, each relating the defect magnitude of the at least one sample object defect to one object lifetime value, and log-linear object lifetime distributions, each relating the defect magnitude of a sample object defect to a plurality of object lifetime values

Provider-initiated HIV counselling and testing (PICT) in the mentally ill

The prevalence of HIV infection is substantially higher in mentally ill individuals than in the general population. Despite this, HIV testing is not yet standard practice among the mentally ill population, and many mental health settings do not encourage HIV testing. This paper discusses provider-initiated HIV counselling and testing (PICT) and some of the ethical dilemmas associated with it, on the basis that PICT may be used to increase the number of mentally ill persons tested for HIV. The authors conclude that PICT should be promoted to all psychiatric admissions and mentally ill individuals receiving outpatient services, and that this is within the parameters of existing policies and legislations in South Africa

Enhancing Facility Layout via Ant Colony Technique (Act)

Cellular manufacturing systems optimization is investigated and manipulated using artificial intelligent (AI) approach combining facility layout and group technology scope. This research applied the ANT COLONY technique  (ACT) optimization where this process was inspired by the real ants and how they move and build colonies by avoiding obstacle and simulate the process to get a procedure that can be adopted on this optimization process. In this research the problem goes in two way first the theory that take account the positions of machines inside the plant and its equations of controlling and second is the routing of part during product life cycle then execute results and applying it on factory configuration. The application of Ants system was carried out on industrial factory of electrical motor where all data was taken from the factory depending on the position and sequence of operations took place. Results were carried out in a way that depending on the showing site plan configurations for each stage and studying the iteration curve response to the parameters changes while testing the system during different environments. The results show high flexibility in ACS (Ant colony system) with fast response and high reduction in the distance crossed by the product part that reached 500m. The ratio of the reduction is 0.625. Keyword: Artificial intelligent (AI), Ant colony (AC), pheromone, genetic algorithm, facility layout, cell manufacturing (CM)

Strengthening of district mental health services in Gauteng Province, South Africa

In response to the Life Esidimeni tragedy, the Gauteng Department of Health established a task team to advise on the implementation of the Health Ombud’s recommendations and to develop a mental health recovery plan. Consistent with international human rights and South African legislation and policy, the plan focused on making mental healthcare more accessible, incorporating a strategy to strengthen district mental health services to deliver community-based care for people with any type and severity of mental illness. The strategy included an organogram with three new human resource teams integrated into the district health system: a district specialist mental health team to develop a public mental health approach, a clinical community psychiatry team for service delivery, and a team to support non-governmental organisation governance. This article discusses the strategy in terms of guiding policies and legislation, the roles and responsibilities of the various teams in the proposed organogram, and its sustainability

Haemorrhaging lesion in the breast: is there a role for embolisation?

Angiosarcoma of the breast is an extremely rare condition. This case illustrates the use of embolisation as a modality of treatment for primary breast angiosarcoma. No other case has been reported on the use of embolisation for this disorder

Medullary carcinoma of the breast: Role of contrast-enhanced MRI in the diagnosis of multiple breast lesions

Medullary carcinoma is a rare breast carcinoma with a syncytial growth pattern and high-grade cytology. It can be difficult to diagnose and may be missed on conventional imaging as the findings may overlap with benign lesions i.e. fibroadenomas. The authors report a case of a 25-year-old female who presented with multifocal breast lumps diagnosed with medullary carcinoma and fibroadenomas. Imaging and pathological correlation with contrast-enhanced MRI are presented in the diagnosis of these lesions

Calcific uraemic arteriolopathy (calciphylaxis) in patients on renal replacement therapy

Background. Calcific uraemic arteriolopathy (calciphylaxis) is an unusual and potentially fatal condition characterised by small-vessel calcification and ischaemic skin necrosis. It mainly affects patients with end-stage renal disease (ESRD) on haemodialysis, but may rarely occur in the absence of ESRD in conditions such as primary hyperparathyroidism, malignancy, alcoholic liver disease and connective tissue disease.Methods. We reviewed the records of all patients diagnosed with calciphylaxis while on renal replacement therapy at Tygerberg Hospital, Cape Town, South Africa, between 1990 and 2014, to describe its presentation, course and final outcome.Results. Nineteen patients developed calciphylaxis over this period. Their median age was 34 years and 13 (68.4%) were female. Fifteen (78.9%) had received a kidney transplant. All patients had painful skin lesions that rapidly progressed to infarction. Small-vessel calcification was seen on skin biopsy in 13 patients. Twelve patients had hyperparathyroidism. Several of the transplanted patients had been treated for graft rejection in the year preceding the diagnosis. Treatment consisted of good wound care and efforts to normalise serum calcium and phosphate levels. Five patients received an urgent parathyroidectomy. The outcome was fatal in 17 patients, with sepsis being the main cause of death.Conclusions. In our patients, calciphylaxis carried a worse prognosis than previously reported internationally. It should always be considered in the differential diagnosis of painful skin lesions in the dialysis or transplant patient