Causation and the concomitant issue of apportionment with reference to gross income in South African income- tax law
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1989
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South African Law Journal
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Juta Law
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University of Cape Town
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Abstract
The objective of this article is twofold: first, to set out the correct role, in our view, of the notion of causation in the application of two elements of the definition of gross income-the characterization of an amount as being from a source within the Republic (or not) and as being of a capital nature (or not); and secondly, to ascertain the apportionment implications where two or more causae with differing tax consequences are found to have given rise to the receipt or accrual of a single amount.
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Reference:
Emslie, T., & Jooste, R. (1989). Causation and the Concomitant Issue of Apportionment with Reference to Gross Income in South African Income-Tax Law. South African Law Journal, 106, 292.