The Taxation of International (non-resident) Sportspersons in South Africa

This thesis tests, firstly, the relevance of the OECD Model article 17 (the sportsperson article). Secondly, and accepting the current format of the sportsperson article in South African Double Tax Agreements (DTAs), the withholding tax applied to sportspersons performing in South Africa is analysed against the sportsperson article to determine whether these are appropriately aligned. The interpretational rules applicable to fiscal legislation in South Africa provide the methodology applied to the analysis of the withholding tax on sportspersons and the applicable DTA articles. Comparative analyses were conducted on all the South African DTAs in force at 1 June 2008 against the OECD, UN and USA Models. The OECD Model provides the core commentary as it is the general basis for most South African DTAs. Substantive analyses were conducted on the DTA articles of 'taxes covered' (OECD Article 2); sportspersons (OECD Article 17) and exchange of information (OECD Article 26). The scope of the withholding tax, both as regards persons and income, was found to be wider than that of the South Africa DTA sportsperson articles. This misalignment renders the withholding tax inapplicable in many cases when applied to a resident of a Contracting State. Naturally the misalignment has no influence on sportspersons from States that have not concluded a DTA with South Africa. The misalignment has also been replicated in the concessionary legislation promulgated for the 2009 FIFA Confederations Cup and 2010 FIFA World Cup in South Africa. As South Africa has not concluded DTAs with the bulk of the potential qualifying countries for the 2010 FIFA World Cup, the possibility of double taxation for sportspersons, support and auxiliary staff is increased. The difference in scope between the DTAs and the withholding tax is also an indicator of the increasing inappropriateness of the sportsperson article in current DTAs in force. While the initial justification for the article's inclusion may have been valid, in a global economy with business and individuals more mobile than national tax systems, an article focussed on only one class of mobile worker is inappropriate and lacks relevance. University of Cape Town Abstract iv As national governments react to global tax issues, development in exchange of information is bound to occur. However, to supplant withholding taxes in source States and to fully support the residence basis of taxation, regular (and reciprocal) exchange of information is required between States. Currently, differences in domestic tax systems and inefficiencies in exchanges render withholding taxes a necessary (albeit a crude) substitute to ensure that the income is taxed at least once between the source State and resident State. Advances in exchange of information are progressing rapidly and it is hoped that automatic relevant exchange of information in the future will remove the need for unnecessary withholding taxes and ensure that the right tax is levied on the right person in the appropriate State (Pocock, 2001). The South African withholding tax on sportspersons should be aligned with the sportsperson article in the interim (or a replacement article in the future). South Africa should also continue to actively pursue exchanges of information with other States and encourage other States to do so in global forums. It is recommended that the DTA sportsperson article be deleted and replaced with a more appropriate and relevant DTA article concerning all mobile individuals

I Synthesis and dynamic studies of bifunctional compounds having potential intramolecular interactions II Controlled release antifouling coatings: Approaches to controlled release of gamma-decanolactone and 2-hexanoylfuran into seawater

I. Potentially reactive, bifunctional compounds 1 and 127 have been studied, and both compounds have been found to undergo rapid base-catalyzed degenerate topomerization. The topomerization processes, which in the case of 1 represents a degenerate transamidation and in the case of 127 a degenerate transesterification, have been studied in acetonitrile-d\sb3 and D\sb2O under a variety of conditions by the DNMR method. In both cases, the presence of a stable tetrahedral anion intermediate can be inferred from analysis of NMR and IR spectra. In the case of 1, the unusually high rate of topomerization can be attributed to the presence of a transannular donor-acceptor interaction and a strained urea functionality. In 127, the rate enhancement is attributed to a favorable entropic situation with respect to an intermolecular reaction of the same type. In addition to the base catalysis studies, acid-catalysis studies of other amino-ureas such as 9 and 10 were carried out in D\sb2O. The rate of topomerization of 10 was slow on the NMR time scale under acid catalysis. The rate of topomerization of 9 could be quantified by a 2D NMR method. II. The release characteristics of biofouling inhibitors 160 and 161 from various ablative and nonablative matrices into artificial seawater have been studied. The goal of these release experiments was to achieve 30-day controlled, sustained release of inhibitor from a matrix into artificial seawater at a level which was considered effective to inhibit fouling of marine surfaces. It was found that encapsulation of 161 in a polymeric matrix and dispersion of 161-containing capsules in a vinyl, nonablative coating provided a successful method for achieving this goal. Release rates of inhibitors 160 and 161 from various matrices are summarized and discussed

Characterization and Genetic Analysis of a Pigmentation Mutant of \u3cem\u3eNeurospora crassa\u3c/em\u3e

The mutant overaccumulator of carotenoids, ovc. was obtained from the Fungal Genetics Stock Center in Kansas City, Kansas. This mutant had been isolated following UV irradiation of the colonial mutant col-4 and mapped to Linkage Group IV (R. Harding, 1984 Neurospora Newsletter 34: 23-25). Examination of ovc in our laboratory revealed that in addition to having increased pigmentation, the mutant was osmotic sensitive, failing to grow on 6% NaCl. Morphology of ovc closely resembles that of cut, another osmotic sensitive mutant in LG IV. A cross of ovc to the osmotic sensitive mutant cut failed to produce recombinant progeny, supporting allelism of the two mutants. Reported location of ovc placed it between col-4 and met-5 in LG IV; however, cut is located to the far left of col-4. Examination of ovc gave no evidence of a translocation in the mutant

Use of the Caulobacter crescentus Genome Sequence To Develop a Method for Systematic Genetic Mapping

The functional analysis of sequenced genomes will be facilitated by the development of tools for the rapid mapping of mutations. We have developed a systematic approach to genetic mapping in Caulobacter crescentus that is based on bacteriophage-mediated transduction of strategically placed antibiotic resistance markers. The genomic DNA sequence was used to identify sites distributed evenly around the chromosome at which plasmids could be nondisruptively integrated. DNA fragments from these sites were amplified by PCR and cloned into a kanamycin-resistant (Kanr) suicide vector. Delivery of these plasmids into C. crescentus resulted in integration via homologous recombination. A set of 41 strains containing Kanr markers at 100-kb intervals was thereby generated. These strains serve as donors for generalized transduction using bacteriophage Cr30, which can transduce at least 120 kb of DNA. Transductants are selected with kanamycin and screened for loss of the mutant phenotype to assess linkage between the marker and the site of the mutation. The dependence of cotransduction frequency on sequence distance was evaluated using several markers and mutant strains. With these data as a standard, previously unmapped mutations were readily localized to DNA sequence intervals equivalent to less than 1% of the genome. Candidate genes within the interval were then examined further by subcloning and complementation analysis. Mutations resulting in sensitivity to ampicillin, in nutritional auxotrophies, or temperature-sensitive growth were mapped. This approach to genetic mapping should be applicable to other bacteria with sequenced genomes for which generalized transducing phage are available

New Forms of Teacher Education: Connections to Charter Schools and Their Approaches

This article critically analyzes the application of charter school techniques in teacher education, especially in two noteworthy programs: the newly developed Relay Graduate School of Education and Match Teacher Residency. We describe how their approaches to teacher preparation differ from traditional teacher education programs. We also raise concern regarding the ways charter-inspired teacher preparation programs overlook the contributions of theory to good teaching, jeopardize teacher flexibility, alter understandings of the professional practice of teaching, and threaten the overarching purpose of educating for democracy that is integral to traditional teacher colleges. We emphasize educationally worthwhile approaches from this new domain of teacher preparation while also offering some words of caution regarding approaches that, given their ties to charter schooling, may be problematically celebrated by the media and public

Semi-supervised learning approach for crack detection and identification in advanced gas-cooled reactor graphite bricks

One of the life-limiting components of an Advanced Gas cooled Reactor (AGR) is its graphite core. The bricks present in the core undergo radiolytic oxidation throughout their lifetime which causes graphite weight loss and irradiation which can result in some of the bricks developing cracks. Understanding the nature and extent of brick cracking within the core is key to ensuring continued and extended operation of the AGR fleet. A semi-supervised machine learning classification algorithm is proposed as a method for improving the detection of cracked graphite bricks, by combining the labels derived from infrequent, detailed inspections of the core, with unlabeled, more frequent monitoring measurements taken during refueling operations. Semi-supervised machine learning, which is an emerging field in nuclear power condition monitoring, is the combination of ideas from both supervised and unsupervised machine learning whereby the data that is used to train the algorithm is a combination of labeled and unlabeled data. This paper introduces the initial research that has been undertaken in creating a semi-supervised self-training algorithm to detect the presence of graphite brick cracks and then proceeds to show that there is an improvement in the classification of graphite bricks using a semi-supervised machine learning classifier compared to supervised machine learning classifiers. This improved classification performance is encouraging as it does not require time consuming and costly human analysis to obtain extra learning information from available data

Development of an assisted-teleoperation system for a dual-manipulator nuclear decommissioning robot

This thesis concerns a robotic platform that is being used for research into assisted tele–operation for common nuclear decommissioning tasks, such as remote handling and pipe cutting. The machine consists of dual, seven–function, hydraulically actuated HYDROLEK manipulators mounted (in prior research) on a mobile BROKK base unit. Whilst the original system was operated by remote control, the present thesis focusses on the development of a visual servoing system, in which the user selects the object of interest from an on–screen image, whilst the computer control system determines and implements via feedback control the required position and orientation of the manipulators. Novel research contributions are made in three main areas: (i) the development of a detailed mechanistic model of the system; (ii) the development and preliminary testing in the laboratory of the new assisted–teleoperation user interface; and (iii) the development of improved control systems for joint angle set point tracking, and their systematic, quantitative comparison via simulation and experiment. The mechanistic model builds on previous work, while the main novelty in this thesis relates to the hydraulic component of the model, and the development and evaluation of a multi–objective genetic algorithm framework to identify the unknown parameter values. To improve on the joystick direct teleoperation currently used as standard in the nuclear industry, which is slow and requires extensive operator training, the proposed assisted–teleoperation makes use of a camera mounted on the robot. Focussing on pipe cutting as an example, the new system ensures that one manipulator automatically grasps the user–selected pipe, and appropriately positions the second for a cutting operation. Initial laboratory testing (using a plastic pipe) shows the efficacy of the approach for positioning the manipulators, and suggests that for both experienced and inexperienced users, the task is completed significantly faster than via tele-operation. Finally, classical industrial, fuzzy logic, and novel state dependent parameter approaches to control are developed and compared, with the aim being to determine a relatively simple controller that yields good performance for the hydraulic manipulators. An improved, more structured method of dealing with the dead–zone characteristics is developed and implemented, replacing the rather ad hoc approach that had been utilised in previous research for the same machine

Impact of real-time ultrasound guidance on complications of percutaneous dilatational tracheostomy: a propensity score analysis

Abstract Introduction Recent studies have demonstrated the feasibility of real-time ultrasound guidance during percutaneous dilatational tracheostomy, including in patients with risk factors such as coagulopathy, cervical spine immobilization and morbid obesity. Use of real-time ultrasound guidance has been shown to improve the technical accuracy of percutaneous dilatational tracheostomy; however, it is unclear if there is an associated reduction in complications. Our objective was to determine whether the peri-procedural use of real-time ultrasound guidance is associated with a reduction in complications of percutaneous dilatational tracheostomy using a propensity score analysis. Methods This study reviewed all percutaneous dilatational tracheostomies performed in an 8-year period in a neurocritical care unit. Percutaneous dilatational tracheostomies were typically performed by trainees under guidance of the attending intensivist. Bronchoscopic guidance was used for all procedures with addition of real-time ultrasound guidance at the discretion of the attending physician. Real-time ultrasound guidance was used to guide endotracheal tube withdrawal, guide tracheal puncture, identify guidewire entry level and confirm bilateral lung sliding. The primary outcome was a composite of previously defined complications including (among others) bleeding, infection, loss of airway, inability to complete procedure, need for revision, granuloma and early dislodgement. Propensity score analysis was used to ensure that the relationship of not using real-time ultrasound guidance with the probability of an adverse outcome was examined within groups of patients having similar covariate profiles. Covariates included were age, gender, body mass index, diagnosis, Acute Physiology and Chronic Health Evaluation II score, timing of tracheostomy, positive end-expiratory pressure and presence of risk factors including coagulopathy, cervical spine immobilization and prior tracheostomy. Results A total of 200 patients underwent percutaneous dilatational tracheostomy during the specified period, and 107 received real-time ultrasound guidance. Risk factors for percutaneous dilatational tracheostomy were present in 63 (32%). There were nine complications in the group without real-time ultrasound guidance: bleeding (n = 4), need for revision related to inability to ventilate or dislodgement (n = 3) and symptomatic granuloma (n = 2). There was one complication in the real-time ultrasound guidance group (early dislodgement). The odds of having an adverse outcome for patients receiving real-time ultrasound guidance were significantly lower (odds ratio = 0.08; 95% confidence interval, 0.009 to 0.811; P = 0.032) than for those receiving a standard technique while holding the propensity score quartile fixed. Conclusions The use of real-time ultrasound guidance during percutaneous dilatational tracheostomy was associated with a significant reduction in procedure-related complications.http://deepblue.lib.umich.edu/bitstream/2027.42/111730/1/13054_2015_Article_924.pd