Dividend payments from employee share scheme trusts

In the past, there has been confusion regarding the taxation of dividends received from employee share scheme trusts. Conflicting interpretations of the definitions in section 8C and certain provisions of 10(1)(k) of the Income Tax Act No. 58 of 1962 (ITA) have caused administrators of these schemes to treat the taxation of dividends in various ways. Section 10(1)(k)(i)(ii) was introduced in the Taxation Laws Amendment Act (TLAA) of 2013 to address the situation where employers are disguising salaries and bonuses as dividend payments to members of employee share scheme trusts. The intention behind this new section 10(1)(k)(i)(ii) is quite clear but it is not entirely certain whether it is having the desired effect as there is still uncertainty around the treatment of dividends from unrestricted equity instruments. The Davis Tax Committee (DTC) published recommendations on the taxation of trusts in its first interim report on estate duty. These recommendations could further complicate matters and have significant tax implications for all the parties involved in these employee share scheme trusts. To try and understand the uncertainty around these dividend payments an analysis was conducted on section 10(1)(k)(i)(dd) and 10(1)(k)(i)(ii) of the ITA. It was also necessary to look at the different types of employee share schemes that are available and also the nature of dividends, dividends withholding tax (DWT) and capital gains tax (CGT). Section 8C and the definitions therein were also analysed to understand the taxation of taxpayers on vesting of equity instruments. A brief look at the treatment of dividend payments from United Kingdom employee share scheme trusts also provided some useful context from an international perspective. Two case studies were conducted to analyse the overall tax effect based on the current tax legislation and also taking into consideration the recommendations made by the first DTC Report

Pre-service teachers' subject knowledge of and attitudes about radioactivity and ionising radiation

This study focussed on secondary school (11-18 years) pre-service teachers’ (n=73) knowledge of and attitudes towards risks associated with alpha, beta and gamma radiations. A multi-method approach was used with physics, chemistry, biology and history graduates undertaking the one year initial teacher training, Post Graduate Certificate in Education (PGCE) course at a university in central England. A novel research tool, involving interviews about real concrete contexts and first hand data collection with radioactive sources, was employed to gain insights into a sub-set of the sample (n=12) of pre-service teachers’ subject knowledge of and attitudes towards risk. The subject knowledge of all the pre-service teachers was also measured using a Certainty of Response Instrument (CRI); multiple choice questions with associated confidence indicators. Although the physicists displayed the higher levels of knowledge, they also demonstrated limitations in their knowledge and held misconceptions such as irradiation being confused with contamination. Physics graduates hold more rational attitudes and a greater willingness to accept risk while the attitudes of graduates in the other subject disciplines are more disparate. These findings raise questions about the extent to which pre-service science and history teachers have the knowledge necessary to teach this topic. The article concludes with discussion of the implications these findings have for initial teacher training, continuing professional development (CPD) needs for teachers already in the profession and curriculum developers

A Model of Mass and Heat Transfer for Disc Temperature Prediction in Open Compressor Cavities

Accurate prediction of heat transfer in compressor cavities is crucial to the design of efficient and reliable aircraft engines. The heat transfer affects the thermal expansion of the compressor rotor and, in turn, the tip clearance of the compressor blades. This paper presents a novel, physically-based predictive theoretical model of heat transfer and flow structure in an open compressor cavity, which can be used to accurately calculate disc temperatures. The radially higher region of the cavity is dominated by buoyancy effects created by the temperature difference between the hot mainstream flow and the axial through flow used to cool the turbine. Strong interaction between the air in the cavity and this through flow creates a mixing region at low radius. For a given geometry, the heat transfer and flow physics are governed by four parameters: the rotational Reynolds number Re ϕ, the buoyancy parameter βΔT, the compressibility parameter χ, and the Rossby number Ro. The model quantifies both the buoyancy- and throughflow-induced mass and heat transfer, producing a reliable prediction of the disc and air temperatures. The model takes into account a two-fold effect of the throughflow: being entrained into the cold radial plumes directly and creating a toroidal vortex in the radially lower region of the cavity. The exchange of mass between the cavity and throughflow is related to the mass flow rate in the radial plumes in the buoyancy-induced region, considering the effect of flow reversal at low Ro. The model is validated using data collected in the Bath Compressor Cavity Rig and can be incorporated in engine design codes to robustly compute the thermal stress and expansion of the compressor rotor, contributing to more efficient engine designs.</p

SB28-21/22: Resolution Demanding the Resignation or Termination of Rob Smith, University of Montana Computer Science Professor

SB28-21/22: Resolution Demanding the Resignation or Termination of Rob Smith, University of Montana Computer Science Professor. This resolution passed unanimously during the October 13, 2021 meeting of the Associated Students of the University of Montana (ASUM)

SB5-21/22: Resolution Standardizing the ASUM Bylaws and House Rules for Proper Formatting and Clarity

SB5-21/22: Resolution Standardizing the ASUM Bylaws and House Rules for Proper Formatting and Clarity. This resolution was unanimously approved during the September 1, 2021 meeting of the Associated Students of the University of Montana (ASUM). Additional attached documents provide context for the content of the resolution as it was seen on the Senate floor

SB9-21/22: Resolution Striking Eight ASUM Committees from the Bylaws and Repurposing the Sustainability Board

SB9-21/22: Resolution Striking Eight ASUM Committees from the Bylaws and Repurposing the Sustainability Board. This resolution passed unanimously during the September 8, 2021 meeting of the Associated Students of the University of Montana (ASUM)

Experimental Investigation of Transient Flow Phenomena in Rotating Compressor Cavities

The clearance of compressor blade tips during aero-engine accelerations is an important design issue for next-generation engine architectures. The transient clearance depends on the radial expansion of the compressor discs, which is directly coupled to conjugate heat transfer in co-rotating discs governed by unsteady and unstable buoyancy-induced flow. This paper discusses an experimental and modelling study using the Bath Compressor Cavity Rig, which simulates a generic axial compressor at fluiddynamically scaled conditions. The rig was specifically designed to generate heat transfer of practical interest to the engine designer and validate computational codes. This work presents the first study of the fundamental fluid dynamic and heat transfer phenomena under transient conditions. The rotating flow structure was seen to be characterised by coherent pairs of cyclonic/anticyclonic vortex pairs; the strength, rotational frequency, stability and number of these unsteady structures changed with changing rotational Reynolds and Grashof numbers during the transients. These structures, measured by unsteady pressure transducers in the rotating frame of reference, were only present when the flow in the rotating cavity was dominated by buoyancy. Experimental correlations of both Nusselt number and radial mass flow rate in the rotating core were correlated against Grashof number. Remarkably, the experiments revealed a consistent correlation for both steady-state and transient conditions over a wide range of Gr. The results have a practical application to thermo-mechanical models for engine design