An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman

dc.contributor.authorNiland, Christopher Barlow
dc.date.accessioned2021-12-14T09:20:07Z
dc.date.available2021-12-14T09:20:07Z
dc.date.issued1990
dc.date.updated2021-12-06T13:05:00Z
dc.description.abstractOur Courts have, in many decisions stretching over decades, been faced with the problem of deciding whether the proceeds of the disposal of certain assets are revenue, or are of a capital nature. The assets which have given rise to the problem are those which one would normally consider to be capital in the hands of the taxpayer, but which may be held to have to have altered in character due to some action of the taxpayer, either by way of a change in the intention of the taxpayer regarding the asset in question, or by virtue of the method adopted by him in the disposal of the asset. The reported cases t dealing with this question arise mainly from the disposal of either shares or immovable property, although this has not always been the case. The principles involved in the inquiry remain the same, no matter what the nature of the asset is, but the application of those principles depends on a number of factors, including the nature of the asset, and of course, the circumstances of the taxpayer.
dc.identifier.apacitationNiland, C. B. (1990). <i>An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman</i>. (). ,Faculty of Law ,Department of Commercial Law. Retrieved from http://hdl.handle.net/11427/35458en_ZA
dc.identifier.chicagocitationNiland, Christopher Barlow. <i>"An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman."</i> ., ,Faculty of Law ,Department of Commercial Law, 1990. http://hdl.handle.net/11427/35458en_ZA
dc.identifier.citationNiland, C.B. 1990. An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman. . ,Faculty of Law ,Department of Commercial Law. http://hdl.handle.net/11427/35458en_ZA
dc.identifier.ris TY - Master Thesis AU - Niland, Christopher Barlow AB - Our Courts have, in many decisions stretching over decades, been faced with the problem of deciding whether the proceeds of the disposal of certain assets are revenue, or are of a capital nature. The assets which have given rise to the problem are those which one would normally consider to be capital in the hands of the taxpayer, but which may be held to have to have altered in character due to some action of the taxpayer, either by way of a change in the intention of the taxpayer regarding the asset in question, or by virtue of the method adopted by him in the disposal of the asset. The reported cases t dealing with this question arise mainly from the disposal of either shares or immovable property, although this has not always been the case. The principles involved in the inquiry remain the same, no matter what the nature of the asset is, but the application of those principles depends on a number of factors, including the nature of the asset, and of course, the circumstances of the taxpayer. DA - 1990_ DB - OpenUCT DP - University of Cape Town KW - Commercial Law LK - https://open.uct.ac.za PY - 1990 T1 - An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman TI - An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman UR - http://hdl.handle.net/11427/35458 ER - en_ZA
dc.identifier.urihttp://hdl.handle.net/11427/35458
dc.identifier.vancouvercitationNiland CB. An inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman. []. ,Faculty of Law ,Department of Commercial Law, 1990 [cited yyyy month dd]. Available from: http://hdl.handle.net/11427/35458en_ZA
dc.language.rfc3066eng
dc.publisher.departmentDepartment of Commercial Law
dc.publisher.facultyFaculty of Law
dc.subjectCommercial Law
dc.titleAn inquiry into 'The nature of capital': with special reference to C.I.R. versus Middelman
dc.typeMaster Thesis
dc.type.qualificationlevelMasters
dc.type.qualificationlevelLLM
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