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The tax consequences of a contingent liability disposed of as part of the sale of a business as a going concern
No full textThe sale of an entity as a going concern has a number of tax consequences for both the purchaser and the seller. The tax deductibility of a contingent liability upon its transfer from the seller to the purchaser, where the selling price has been reduced by the value of the contingent liabilities transferred, remains uncertain following the decision in Ackermans Ltd v Commissioner for the South African Revenue Service.
An expense is either deductible under a specific section of the Income Tax Act, 58 of 1962, or under the general expense provisions in terms of sections 11(a) and 23(g). The Act does not contain a specific section relating to contingent liabilities and therefore a contingent liability will need to be considered for deduction under these sections. The Act further disallows an expense as a deduction under section 23(e), where a reserve is created (for example a leave pay provision).
This study analyses the tax deductibility of a contingent liability, where the contingent liability has been transferred from the seller to the purchaser in a sale of an entity as a going concern and the purchase price has been reduced to compensate for the transfer of the contingent liability. The deductibility of the contingent liability was first assessed in terms of the provisions of the Act (sections 11(a), 23(g) and 23(e)) and associated case law. The decision in the Ackermans case and its preceding Income Tax Case 1839 was then analysed in order to establish the principles arising from the decisions. Finally the proposals in the Draft Taxation Laws Amendment Bill, 2011, and the subsequent Discussion Document issued by the South African Revenue Service were discussed.
The analysis revealed the continuing confusion surrounding the status quo, thus demonstrating the importance of legislative intervention to provide guidelines for taxpayers
Reconceptualising notions of South African Indianess : a personal narrative
No full textThe theoretical challenge of conceptualising South African Indianess is suffused with a plethora of variables that suggest complexity. While being misleadingly homogenous, Indian identity encompasses a multitude of expressions. This thesis seeks to reconceptualise notions of South African Indianess through personal narrative. The research context is contemporary South Africa with a specific focus on Johannesburg’s East Rand Reef. Inspired by the dearth of literature on contemporary Indianess this study addresses the gap in the present discourse. Following the autoethnographic work of Motzafi-Haller (1997) and Narayan (1993) the thesis presents a layered narrative by juxtaposing the experiences of research participants with my own. Using multi-sited autoethnographic data the thesis explores the question of what it means to be Indian in relation to South Africa’s Apartheid past. By drawing on concepts in popular diaspora theory and critiquing their application, the thesis illustrates the inadequacies inherent in the definitions of diaspora and suggests a broader understanding of its application. Through exploring layers of Indianess the thesis illustrates the inherent complexity in reconceptualising South African Indianess. The study suggests that as a result of changing global and local flows, South African Indians are reconceptualising what it means to be South African Indian
Sport consumption patterns in the Eastern Cape : cricket spectators as sporting univores or omnivores
No full textSince its inception, consumption behaviour theory has developed to account for the important social aspect that underpins or at least to some extent can be used to explain consumption behaviour. Modern consumption behaviour theory is anthropocentric in nature, with people and societal influence at the forefront of the theory. To date, empirical studies on consumption behaviour of cultural activities (for example, music and arts), entertainment and sport have used Bourdieu’s (1984) omnivore/univore theory to suggest that consumption of leisure activities is bound up in social ties. To date, no such investigation has been conducted in the context of sport in South Africa. The aim of the study therefore is to investigate whether South African cricket spectators are sporting omnivores or univores, thus, essentially investigating whether sports consumption behaviour in South Africa is bound up in social ties.
A number of positive economic and social ramifications could result from gaining a holistic understanding of sports consumption behaviour in South Africa. Given these ramifications, the secondary goal of the research is to identify motives for consumers making specific sport consumption decisions, and determining whether certain characteristics can be attributed to these consumption decisions. Recommendations based on the findings of the research could help various stakeholders understand sports consumption patterns in South Africa, which could in turn lead to the realization of positive economic and social benefits.
The study made use of a questionnaire, administered at four different limited overs cricket matches in the 2012/13 cricket season, to obtain a range of responses reflecting specific types of consumption behaviour as well as motives for consumption decisions of cricket spectators in the Eastern Cape. Using individual binary probit models and post estimation F-tests, the results indicate that consumption behaviour of sport within South Africa predominantly differs on the grounds of education and race. This suggests that there are aspects of social connotations underpinning sports consumption behaviour within South Afric
Application of Baylis-Hillman methodology in the synthesis of HIV-1 enzyme inhibitors
No full textThe application of Baylis-Hillman methodology has afforded access to a range of β-hydroxypropionate ester-AZT conjugates as potential dual-action HIV-1 IN/RT inhibitors. Two
families comprising a total of nine β-hydroxypropionate ester-AZT conjugates were synthesised.
The first family was accessed using O-benzylated salicylaldehydes and methyl acrylate and the
second from unprotected salicylaldehydes using tert-butyl acrylate as the activated alkene.
Spectroscopic methods were employed to fully characterize the compounds. Propargylation of
the respective Baylis-Hillman adducts was achieved via conjugate addition of propargylamine.
The resulting products were then employed in Cu(I)-catalysed “click” reactions with
azidothymidine (AZT) to yield the desired β-hydroxypropionate ester-AZT conjugates.
Exploratory studies were also conducted to access 4-hydroxycoumarins from Baylis-Hillman
derived adducts and to construct customized chiral Baylis-Hillman reaction sites. Many 4-
hydroxycoumarins are known to exhibit a wide range of biological activities, and extending
Baylis-Hillman methodology to access these systems is an important challenge. Two approaches
were investigated. The first involved the formation of a 4-phthalimidocoumarin, aromatisation
and hydrolysis of which was expected to lead to the 4-hydroxycoumarin target. The second, a
variation of the first, involved the use of 4-(chrolomethyl)coumarin intermediates. Unfortunately,
while various intermediates were prepared and characterised, neither approach led ultimately to
the desired targets. N-substituted borneol-10-sulfonamides were constructed from camphor-10-
sulfonyl chloride as chiral Baylis-Hillman reaction sites. In a preliminary study, however, none
of the N-substituted borneol-10-sulfonamides exhibited Baylis-Hillman catalytic activity
An in-silico investigation of Morita-Baylis-Hillman accessible heterocyclic analogues for applications as novel HIV-1 C protease inhibitors
No full textCheminformatic approaches have been employed to optimize the bis-coumarin scaffold
identified by Onywera et al. (2012) as a potential hit against the protease HIV-1 protein. The
Open Babel library of commands was used to access functions that were incorporated into a
markov chain recursive program that generated 17750 analogues of the bis-coumarin
scaffold. The Morita-Baylis-Hillman accessible heterocycles were used to introduce
structural diversity within the virtual library. In silico high through-put virtual screening
using AutoDock Vina was used to rapidly screen the virtual library ligand set against 61
protease models built by Onywera et al. (2012). CheS-Mapper computed a principle
component analysis of the compounds based on 13 selected chemical descriptors. The
compounds were plotted against the principle component analysis within a 3 dimensional
chemical space in order to inspect the diversity of the virtual library. The physicochemical
properties and binding affinities were used to identify the top 3 performing ligands. ACPYPE
was used to inspect the constitutional properties and eliminated virtual compounds that
possessed open valences. Chromene based ligand 805 and ligand 6610 were selected as the
lead candidates from the high-throughput virtual screening procedure we employed.
Molecular dynamic simulations of the lead candidates performed for 5 ns allowed the
stability of the ligand protein complexes with protease model 305152. The free energy of
binding of the leads with protease model 305152 was computed over the first 50 ps of
simulation using the molecular mechanics Poisson-Boltzmann method. Analysis structural
features and energy profiles from molecular dynamic simulations of the protein–ligand
complexes indicated that although ligand 805 had a weaker binding affinity in terms of
docking, it outperformed ligand 6610 in terms of complex stability and free energy of
binding. Medicinal chemistry approaches will be used to optimize the lead candidates
before their analogues will be synthesized and assayed for in vivo protease activity
Phthalocyanine-nanoparticle conjugates for photodynamic therapy of cancer and phototransformation of organic pollutants
No full textThe synthesis and extensive spectroscopical characterization of novel phthalocyanines are reported. The new compounds were characterized by elemental analysis, FT-IR, ¹HNMR, mass spectrometry and UV–Vis spectroscopy. The new phthalocyanines showed remarkable photophysicochemical behaviour. The novel phthalocyanines were then conjugated to nanoparticles, silver and ZnO. The coupling of the novel Pcs to nanoparticles was through covalent bonding and ligand exchange. These conjugates were supported onto electrospun polystyrene fibers and chitosan microbeads for use as photocatalysts. The efficiency of the immobilized Pcs and Pc-nanoparticles was assessed by the phototrasfromation of organic pollutants, methyl orange and Rhodamine 6G as model dyes. Upon conjugating phthalocyanines to nanoparticles, there was a great increase in the rate of photodegradation of the model dyes.
The photodynamic activity of the novel phthalocyanines upon conjugating to nanoparticles and selected targeting agents is also reported. The targeting agents employed in this study are folic acid and polylysine. Conjugating the phthalocyanines to folic acid or polylysine improved the solubility of the phthalocyanines in aqueous media. The potency of the conjugates was investigated on breast (MCF-7), prostate and melanoma cancer cell lines. The phthalocyanines showed no toxicity in the absence of light. However, upon illumination, a concentration dependent cellular decrease was observed
Professional development among counselling psychology interns : exploring critical incidents
No full textThe journey towards becoming a counselling psychologist, in South Africa, includes the
completion a 12 month internship. The internship year holds many challenges and demands
for novice professionals and aims to assist them in making the transition from student to
professional. This study aims to explore the subjective experiences of intern counselling
psychologists and the critical incidents which assist them in making this transition. In
addition, it aims to identify experiences impacting on the interns’ professional development
and professional identity. Three registered counselling psychologists, who completed their
internship at a South African university counselling centre within the last year, were recruited
and participated in individual interviews. These interviews were semi-structured and
followed the Critical Incident Technique method. Each interview was voice recorded and
transcribed. The data collected was analysed using thematic content analysis. As the research
design is qualitative, using a phenomenological approach, the focus is on presenting
information-rich and detailed descriptions of participants “lived” experiences of their
internship year. It attempts to understand significant incidents or events which influenced the
participants’ professional and personal development as they navigate through this ambiguous
period to become independent and ethical practitioners. Four predominant themes emerged
from the data collected, which include a discussion pertaining to professional boundaries and
limitations, learning within the internship environment, the effects of professional and
personal support and, lastly, the transition from dependent to independent professional
functioning
Bitten
No full textMy poetry investigates the extraordinary in the everyday, exploring my life as a mother and wife, to find the quiet truths that lie there. Using fresh ways of describing familiar experiences, the poems describe tiny, almost-missed moments and voices that have shaped me. Throughout the collection, I imagine my younger selves commenting on my current self and vice versa. Ultimately, my poems use simple words and clean lines to evoke how I feel (and how I want the reader to feel) in each of the moments they describ
An evaluation of the potential for implementing adaptive co-management in the Waodani social-ecological system in the Ecuadorian Amazon
No full textAdaptive co-management (ACM), one of the most prominent management approaches to emerge in the recent years, combines iterative learning, flexibility, and adaptation promoted by adaptive management with the principles of nurturing diversity and fostering collaboration among different partners that underpin co-management philosophy. ACM has been proposed as an approach to address the deficiencies of centralized management in ensuring sustainability of social-ecological systems (SESs) in face of future uncertainties. This thesis aims to evaluate the readiness of resource users (the Waodani) as well as external actors (the Ecuadorian State and NGOs) for future implementation of ACM and thus enhancing the long-term social-ecological sustainability of the Waodani SES located in the Yasuni Biosphere Reserve in the Ecuadorian Amazon. Qualitative data obtained by means of focus groups with the Waodani and individual interviews with external actors and Waodani leaders revealed different levels of readiness for ACM. Firstly, in the case of the Waodani, the insufficient fulfillment of some conditions required for successful ACM as well as intercommunity differences in regards to these conditions can complicate the implementation of ACM, unless sufficient external assistance is offered to the SES. The analysis of NGOs demonstrated, on the other hand, a relative readiness for ACM, providing that such aspects as sufficient funding, long-term commitment to collaboration, and inter-institutional linkages are strengthened. The study also found that the Ecuadorian government’s potential to contribute to ACM is hindered by the lack of readiness to work with the indigenous society as well as by funding and communication challenges. Furthermore, the resource based economy supported by the State limits the scope of innovation and adaptation. Still, as in the case of other actors, overcoming the challenges and transitioning towards adaptive governance and thus ACM could be possible in the long-term, if recent legal and political changes are truly implemented
Applications of Social Media and Web 2.0 for Research Support in Selected African Academic Institutions
Get PDFThis study examined the use of Social Media/Web 2.0 for research support and it is guided by three objectives namely: a) to ascertain the uses of social media in academic institutions; b) to identify the challenges associated with social media use for research purposes and c) to provide experiences of social media application in selected African academic institutions. The study makes use of literature analysis in combination with personal and professional work experiences on the use of social media from librarians in four different countries. Institutional experiences of the four librarians showed that it is only Rhodes University Library that uses social media in its library, which is as a result of a formal social media strategy. For the other three universities, University of Education, Winneba Library in Ghana, Makerere University Library in Uganda and the University of Nigeria Library, the use of social media is not encouraging. They use it mostly for communication and interaction with colleagues. It was also discovered that there is no social media strategy available in these university libraries. Based on these findings, the study recommended the implementation of a social media strategy, appointment of social media librarians in these libraries, and continuing professional development of librarians to keep abreast with current trends. Web 2.0/Social Media is a new technology offering new options for African academic librarians in their research support rol