Wessels Greyling

🇺🇦 for the win

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Do you remember when you joined X? I do! #MyXAnniversary

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@jaysqueezi @thejoshviljoen @devlouw @AndreBothmaTax Section 9 was done specifically for this reason. It was done to show SARS doesn’t care about strategic objectives.

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@jaysqueezi @thejoshviljoen @devlouw @AndreBothmaTax Because your initial reason for buying the share did not materialise and you sell the share Sec 9 still applies. Your cost price does increase though if you capitilised the divi. If you sell it at a loss the loss is deductible from other income.

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@jaysqueezi @thejoshviljoen @devlouw @AndreBothmaTax I think you are trying to over complicate matters. Let’s try it from a different angle. What would you say would make a this type of transaction capital in nature? Then we can discuss the merits?

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@thejoshviljoen @jaysqueezi @devlouw @AndreBothmaTax The old tax court cases do not supersede new tax laws. This section in particular is very new. It will be interesting to know however which tax case law will be the foundation as an argument against Section 9(C) for you?

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@jaysqueezi @devlouw @thejoshviljoen I gather that your experience regarding this is very limited. To quote your words “hard and fast”, the ITA is “hard and fast” on this issue. I am familiar with this circular and it unfortunately does not address the issue as you wish it should.

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@jaysqueezi @devlouw @thejoshviljoen The link posted may lead to confusion to those not closely familiar with the ITA. It should be noted that these “circulars” is a source for “easier reading”. It cannot be used as a legal source for basing an opinion. Contact a Tax Practitioner rather.

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@jaysqueezi @devlouw @thejoshviljoen Kindly supply me with a legal binding ruling or a section of the ITA to substantiate your statement.

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@jaysqueezi @devlouw @thejoshviljoen Section 9C(5) of the Income Tax Act.

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@jaysqueezi @devlouw @thejoshviljoen If it’s less than 3 years you will be taxed at your marginal personal income tax rate, not CGT.

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@CAPITALSIGMAza @thejoshviljoen If you bought a share for 1 USD at 8 ZAR and the share is still worth 1 USD @ ZAR 19, you’ll pay CGT on the R11 difference (Longer than 3 years). If you had the money in a USD bank @ 8 ZAR and repatriated it at 19 ZAR there is no taxes at all.

[Wessels Greyling @WesselsGreyling]

@CAPITALSIGMAza @thejoshviljoen Nope, on realisation of that asset you are obliged to disclose it on your ITR. The SARB knows everything and sends it to SARS.

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Do you remember when you joined X? I do! #MyXAnniversary

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SitRep - 15/11/23 - Control over Kynky is expanding

An overview of the daily events in Russia's invasion of Ukraine. On the left bank, Ukraine is expanding its area of control in Krynky, and fighting in the Kupyansk and Avdiivka directions continue heavily.

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SitRep - 13/11/23 - More Gepards for Ukraine

An overview of the daily events in Russia's invasion of Ukraine. US bought 60 Gepards from Jordan which are highly needed for Ukrainian air defense during winter.

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[NOELREPORTS 🇪🇺 🇺🇦 @NOELreports]

SitRep - 10/11/23 - The left bank is getting hotter and hotter... 🔥

An overview of the daily events in Russia's invasion of Ukraine. On the left bank, the AFU is expanding their zone(s) of control, including a new axis...

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[NOELREPORTS 🇪🇺 🇺🇦 @NOELreports]

SitRep - 08/11/23 - Activity on the left bank

An overview of the daily events in Russia's invasion of Ukraine. Ukrainian troops have a strong foothold in some parts of the left bank. Also the start of negotiations with the EU on accession is confirmed.

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@Jon_M_Berger Ignore

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@oryxspioenkop Are you South African? Or is there another reason for the “spioenkop” part of your name? I am South African and Afrikaans. Spioenkop means “spy head” but the specific place in SA is where the boers “farmers” had a war against the English.