A discussion of the concept, “place of effective management” and the proposed changes, in the context of South African tax law

The concept, “place of effective management”, is used in South African tax legislation to determine the residency of companies and it is also used by the Organisation for Economic Co-operation and Development (OECD) and in many tax treaties as a tie-breaker clause to determine the residency of companies that may appear to be dual resident or to determine which country has the taxing rights to income that may be subject to double tax due to the income being from a source outside of the company’s country of residence. The concept is not defined in any tax legislation and there is no uniform interpretation of the concept globally. The former guidance provided by the South African Revenue Services (SARS) adopted a hierarchal approach and the focus was the implementation of the Board of Directors’ decisions. This interpretation was not aligned to the guidance of the OECD whose focus is the place where the key management and commercial decisions of the entity are made. The current SARS guidance has been aligned to the OECD guidance and, essentially, the core principle is to determine who makes the key commercial and management decisions of the company and the place where these individuals are making these decisions. The current SARS and OECD guidance have now been aligned. The current SARS and OECD interpretations have been found to be a more effective tie-breaker clause than the former interpretations

The Difference Between Teacher Candidates’ and Veteran Teachers’ Perceptions of Motivation

In this study, motivational levels and self-efficacy of educators are assessed as a case study. Twenty-two participants were divided into three subgroups engaged in the study. The subgroups included a group of teacher candidates who had recently declared their majors, a group of teacher candidates who had completed all of their coursework, and a group of veteran teachers who had completed a formal teacher education evaluation system. An academic motivational scale was administered to determine if the participants are extrinsically or intrinsically motivated to be an educator. In addition, a teacher self-efficacy scale was administered to distinguish the self-efficacy beliefs and identify their strength in either student engagement, instructional strategies, or classroom management. Open-ended interviews were the primary data collection tool used to gain in-depth information on the environmental factors that the participants have in common. The key findings from this research imply that teacher candidates and veteran teachers are more extrinsically motivated than they are intrinsically motivated. The results indicate that the teacher candidates have an equal confidence in their student engagement, instructional strategy, and classroom management abilities, whereas veteran teachers are more confident in their student engagement abilities. The themes that all of the participants had in common are: connection with the students, socioeconomic status having no economic bearing, innate satisfaction, experiencing being burnt out, job security, family influence, and prior teaching experiences that contributed to their decision to enter the field of education

Computation of the expected value of a function of a chi-distributed random variable

We consider the problem of numerically evaluating the expected value of a smooth bounded function of a chi-distributed random variable, divided by the square root of the number of degrees of freedom. This problem arises in the contexts of simultaneous inference, the selection and ranking of populations and in the evaluation of multivariate t probabilities. It also arises in the assessment of the coverage probability and expected volume properties of the some non-standard confidence regions. We use a transformation put forward by Mori, followed by the application of the trapezoidal rule. This rule has the remarkable property that, for suitable integrands, it is exponentially convergent. We use it to create a nested sequence of quadrature rules, for the estimation of the approximation error, so that previous evaluations of the integrand are not wasted. The application of the trapezoidal rule requires the approximation of an infinite sum by a finite sum. We provide a new easily computed upper bound on the error of this approximation. Our overall conclusion is that this method is a very suitable candidate for the computation of the coverage and expected volume properties of non-standard confidence regions

A guided neural network approach to predict early readmission of diabetic patients

Diabetes is a major chronic health problem affecting millions globally. Effective diabetes management can reduce the risk of hospital readmission and the associated financial losses for both the healthcare system and insurance companies. Hospital readmission is a high-priority healthcare quality measure that reflects the inadequacies in the healthcare system that also increase healthcare costs and negatively influence hospitals’ reputation. Predicting readmissions in the early stages prompts great attention to patients with a high risk of readmission. There has been some attempt in applying machine learning predictive models such as ensemble learning with Extreme Gradient Boosting (XGBoost), Support Vector Machine (SVM) and Artificial Neural Networks (ANN) to correctly identify if the readmission can happen within 30 days (< 30 days) or it may never happen or happens after 30 days ( ≥30 days). We are proposing a new method that is applied to ANN to guide it through its gradient descent optimizers by realizing consistent vs inconsistent data in every batch. Our results show that there are up to 1.5% improvement in classification accuracies in both 2-class and 3-class variations of the experimented benchmark dataset when using the guided optimizer to train the ANN as opposed to the standard optimizer. Guided ANN is also able to achieve better error convergence than standard ANN

The Adoption of Information Technology in the Governance System of the Bank of Namibia

The failure of many organisations over the years has led to a greater need for transparency and accountability. The Corporate Governance Framework, as developed by the King report, is the overarching framework that ensures that the board of directors are responsible for the governance of an organisation. The King III report implies that the board should also be responsible for IT governance because IT is a crucial and costly component that enables the achievement of organisational objectives. From several IT Governance frameworks that exist, the Bank of Namibia, through its integration initiative with the SADC Central Banks, has adopted COBIT 4.1 as an IT governance framework. COBIT 4.1 has several processes that directly aid the alignment of IT to business. A study of the implementation approach of the framework at the Bank and its effectiveness in ensuring the alignment of IT to the business functions was conducted. This study used a quantitative research methodological approach. A questionnaire was developed and was completed using a stratified sample of 35 individuals chosen from a target population comprised of the IT department, executive management and IT compliance champions in the Bank. The findings from the study revealed that a good understanding of what corporate and IT governance entails was evident in the Bank. Ninety-seven percent of the respondents indicated that IT is a key strategic tool that can be leveraged to achieve business goals. In the age of changing technology, the study revealed that the IT department is innovative and stays abreast with new technologies and trends. User awareness was not adequate and the study further revealed that only 49% of the respondents were involved in the IT governance project. The study revealed that top management supported the project. The study also reflected the positive role of IT auditing in the project. It was also noted that IT service delivery has improved and that benchmarking initiatives, as a result of the project, can lead to significant improvements in IT operations. The study revealed that the IT department understands business needs through a process facilitated by their annual departmental visits. The results from the departmental visits are well prioritised projects and IT projects that are tailored to support business goals. An IT steering committee, which was formulated, ensures that executive management is involved in key IT decisions and the reports on IT governance to the board and ensures that awareness is raised on that platform. It is recommended that an IT user awareness programme be established and an investment framework should also be established. It is recommended that the Bank adopts the COBIT 5 framework, which is a more holistic approach that focuses on governance as well as allowing for greater alignment between IT and business functions