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

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

Detection and characterisation of papillomavirus in skin lesions of giraffe and sable antelope in South Africa

Papillomavirus was detected electron microscopically in cutaneous fibropapillomas of a giraffe (Giraffa camelopardalis) and a sable antelope (Hippotragus niger). The virus particles measured 45 nm in diameter. Histopathologically, the lesions showed histopathological features similar to those of equine sarcoid as well as positive immunoperoxidase-staining of tissue sections for papillomavirus antigen. Polymerase chain reaction (PCR) detected bovine papillomavirus (BPV) DNA. Bovine papillomavirus-1 was characterised by real-time PCR in the sable and giraffe, and cloning and sequencing of the PCR product revealed a similarity to BPV-1. As in the 1st giraffe, the lesions from a 2nd giraffe revealed locally malignant pleomorphism, possibly indicating the lesional end-point of papilloma infection. Neither virus particles nor positively staining papillomavirus antigen could be demonstrated in the 2nd giraffe but papillomavirus DNA was detected by real-time PCR which corresponded with BPV-1 and BPV-2

Bacterial diversity of biofilm samples from deep mines in South Africa

The Au, Pt and diamond mines of South Africa provide access to microorganism bearing fluids emanating from fractures at depths ranging from 0.7 to 3.2 km. Due to the unique characteristic of mine environment as demonstrated by extreme pH, pressure, temperatureand/or salinity, it is anticipated that it could hold the promise for novel gene sequences and hence gene products of industrial and pharmaceutical importance. To provide insight into themicrobial diversity of mines in South Africa, biofilm samples were collected from Goldfield and diamond mines and their bacterial diversity determined using molecular approaches. 16S rRNA genes were amplified from DNA extracted from these samples using polymerase chain reaction with universal bacterial primers 27F (5’- AGA GTT TGA TCM TGG CTC AG-3’) and 1492R (5’- GGT TAC CTT GTT ACG ACT T-3’). Metagenomic clone libraries were constructed and restriction fragment length polymorphism (RFLP) analysis of >100 derivedclones resulted in four major restriction patterns from which 40 clones were chosen for sequencing. More than half (53%) of the sequences were affiliated with the bacterial phylum Proteobacteria, forty-one percent (41%) of the sequences with yet uncultured bacteria andthe phyla Firmicutes and Planctomycetes were accounted for by 4% and 2% of the sequences respectively. DGGE analysis of PCR-amplified 16S rRNA genes showed characteristic fingerprints for each sample. The differences in community structure observed account for the uniqueness of each of the mines with respect to its microbial diversity

Evaluation of tuberculosis diagnostic test accuracy using Bayesian latent class analysis in the presence of conditional dependence between the diagnostic tests used in a community-based tuberculosis screening study

Diagnostic accuracy studies in pulmonary tuberculosis (PTB) are complicated by the lack of a perfect reference standard. This limitation can be handled using latent class analysis (LCA), assuming independence between diagnostic test results conditional on the true unobserved PTB status. Test results could remain dependent, however, e.g. with diagnostic tests based on a similar biological basis. If ignored, this gives misleading inferences. Our secondary analysis of data collected during the first year (May 2018 -May 2019) of a community-based multi-morbidity screening program conducted in the rural uMkhanyakude district of KwaZulu Natal, South Africa, used Bayesian LCA. Residents of the catchment area, aged >/=15 years and eligible for microbiological testing, were analyzed. Probit regression methods for dependent binary data sequentially regressed each binary test outcome on other observed test results, measured covariates and the true unobserved PTB status. Unknown model parameters were assigned Gaussian priors to evaluate overall PTB prevalence and diagnostic accuracy of 6 tests used to screen for PTB: any TB symptom, radiologist conclusion, Computer Aided Detection for TB version 5 (CAD4TBv5>/=53), CAD4TBv6>/=53, Xpert Ultra (excluding trace) and culture. Before the application of our proposed model, we evaluated its performance using a previously published childhood pulmonary TB (CPTB) dataset. Standard LCA assuming conditional independence yielded an unrealistic prevalence estimate of 18.6% which was not resolved by accounting for conditional dependence among the true PTB cases only. Allowing, also, for conditional dependence among the true non-PTB cases produced a 1.1% plausible prevalence. After incorporating age, sex, and HIV status in the analysis, we obtained 0.9% (95% CrI: 0.6, 1.3) overall prevalence. Males had higher PTB prevalence compared to females (1.2% vs. 0.8%). Similarly, HIV+ had a higher PTB prevalence compared to HIV- (1.3% vs. 0.8%). The overall sensitivity for Xpert Ultra (excluding trace) and culture were 62.2% (95% CrI: 48.7, 74.4) and 75.9% (95% CrI: 61.9, 89.2), respectively. Any chest X-ray abnormality, CAD4TBv5>/=53 and CAD4TBv6>/=53 had similar overall sensitivity. Up to 73.3% (95% CrI: 61.4, 83.4) of all true PTB cases did not report TB symptoms. Our flexible modelling approach yields plausible, easy-to-interpret estimates of sensitivity, specificity and PTB prevalence under more realistic assumptions. Failure to fully account for diagnostic test dependence can yield misleading inferences

Making use of an existing questionnaire to measure patient-centred attitudes in undergraduate medical students : a case study

CITATION: Archer, E., Bezuidenhout, J., Kidd, M. & Van Heerden, B.B. 2014. Making use of an existing questionnaire to measure patient-centred attitudes in undergraduate medical students: A case study. African Journal of Health Professions Education, 6(2):150-154, doi:10.7196/ajhpe.351.The original publication is available at http://www.ajhpe.org.zaBackground. Patient-centred care is widely acknowledged as important to achieve improved patient outcomes in healthcare. Therefore, it is vital that medical schools should foster this attitude in their students. Studies report that students are becoming less patient-centred in the period between entry to medical school and graduation. Objective. To determine the shift in attitude towards patient-centredness in a group of South African undergraduate medical students. Simultaneously, the reliability and validity of the Patient-Practitioner Orientation Scale (PPOS) in our context were measured. Methods. A cross-sectional survey was undertaken by asking all the medical students from year 1 to year 6 to complete the PPOS. The mean PPOS score for each cohort was calculated using SPSS for Windows. Reliability and validity testing was conducted using Cronbach’s alpha and confirmatory and exploratory factor analysis. Results. The average return rate across the 6 years of study was 81%. The results indicated low initial scores on the PPOS and a decrease in scores over the years of study, with the most dramatic drop being from year 1 to year 2. The PPOS showed poor validity and reliability in our context. Conclusion. The study appears to indicate the same decrease in patient-centredness in our students as has been shown in other studies using this tool. However, the low reliability and validity of the PPOS in our environment means that the result should be interpreted with caution. Factors such as our medical students’ not having had first-hand experience of the doctor-patient relationship and second-language issues may play a role. It is recommended that the PPOS not be used in our context without further exploration of the factors contributing to this loss of reliability and validity.http://www.ajhpe.org.za/index.php/ajhpe/article/view/351Publisher's versio

Virulence of South African isolates of Haemophilus paragallinarum. Part 3: Experimentally produced NAD-independent isolate

A NAD-dependent isolate 46 (C-3) of Haemophilus paragallinarum, which was previously demonstrated to be of high virulence, was transformed to NAD independence using a plasmid isolated from a naturally occurring NAD-independent isolate of H. paragallinarum. The transformation was performed by two different methods and the identity of all of the isolates, before and after transformation was confirmed using a H. paragallinarum-specific PCR test. The transformed NAD-independent serovar C-3 isolate and the wild-type serovar C-3 isolate were used to experimentally infect vaccinated layer chickens. It was shown that the transformation to NAD independence significantly altered the virulence of the serovar C-3 isolate that was used in the transformation experiment. The mechanisms responsible for a decrease in virulence are not clear, but may be related to the pathology of the transformed isolate in the sinus of the chickens.The articles have been scanned in colour with a HP Scanjet 5590; 600dpi. Adobe Acrobat v.9 was used to OCR the text and also for the merging and conversion to the final presentation PDF-format.mn201

Fantasy proneness, but not self-reported trauma is related to DRM performance of woman reporting recovered memories of childhood sexual abuse

Extending a strategy previously used by Clancy, Schacter, McNally, and Pitman (2000), we administered a neutral and a trauma-related version of the Deese-Roediger-McDermott paradigm to a sample of women reporting recovered (n = 23) or repressed memories (n = 16) of childhood sexual abuse (CSA), women reporting having always remembered their abuse (n = 55), and women reporting no history of abuse (n = 20). We found that individuals reporting recovered memories of CSA are more prone than other participants to falsely recalling and recognizing neutral words that were never presented. Moreover, our study is the first to show that this finding even held when trauma-related material was involved. Correlational analyses revealed that fantasy proneness, but not self-reported traumatic experiences and dissociative symptoms were related to false recall and false recognition

Improved ventricular function during inhalation of PGI(2) aerosol partly relies on enhanced myocardial contractility

Inhaled prostacyclin (PGI(2)) aerosol induces selective pulmonary vasodilation. Further, it improves right ventricular ( RV) function, which may largely rely on pulmonary vasodilation, but also on enhanced myocardial contractility. We investigated the effects of the inhaled PGI(2) analogs epoprostenol (EPO) and iloprost (ILO) on RV function and myocardial contractility in 9 anesthetized pigs receiving aerosolized EPO (25 and 50 ng center dot kg(-1) center dot min(-1)) and, consecutively, ILO (60 ng center dot kg(-1) center dot min(-1)) for 20 min each. We measured pulmonary artery pressure ( PAP), RV ejection fraction (RVEF) and RV end-diastolic-volume (RV-EDV), and left ventricular end-systolic pressure-volume-relation (end-systolic elastance, E-es). EPO and ILO reduced PAP, increased RVEF and reduced RVEDV. E-es was enhanced during all doses tested, which reached statistical significance during EPO25ng and ILO, but not during EPO50ng. PGI(2) aerosol enhances myocardial contractility in healthy pigs, contributing to improve RV function. Copyright (C) 2005 S. Karger AG, Basel