A comparison of tax legislation of trusts between South Africa and the United States of America on emigration

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dc.contributor.advisor Stark, K.
dc.contributor.coadvisor Cronje, M.
dc.contributor.postgraduate Lottering, Natasia en
dc.date.accessioned 2013-09-09T07:23:05Z
dc.date.available 2012-05-18 en
dc.date.available 2013-09-09T07:23:05Z
dc.date.created 2012-04-16 en
dc.date.issued 2012-05-18 en
dc.date.submitted 2012-03-06 en
dc.description Dissertation (MCom)--University of Pretoria, 2012. en
dc.description.abstract An estimated 81 142 South Africans emigrated to the United States of America in 2010 (The World Bank, 2010). If only one of these emigrants were a creator, donor or beneficiary of a South African trust, then it is important to determine the tax implications both in South Africa and the United States of America for the creator, donor or beneficiary. In South Africa, the income and gains of the South African trust will be taxed in the hands of the donor, beneficiary or the trust itself. But, in the United States of America, the tax consequences could get rather complicated. The main purpose of this study was to make a theoretical comparison of the tax consequences of South African trusts both in South Africa and the United States of America and determine the effect of the emigration of the South African donor and/or beneficiaries to the United States of America. Based on the literature reviewed, the donor will be taxed in South Africa if a donation, settlement or other disposition was made, the beneficiary will be taxed if he/she has a vested right to income and no donation, settlement or other disposition was made and the South African trust will be taxed on any taxable income retained in the trust that is not taxable in the hands of the donor or beneficiary. In the United States of America, the South African trust will be liable for tax depending on its status as a business, investment or ordinary trust and furthermore on its status as a grantor or non-grantor trust. en
dc.description.availability Unrestricted en
dc.description.department Taxation en
dc.identifier.citation Lottering, N 2012, A comparison of tax legislation of trusts between South Africa and the United States of America on emigration, MCom dissertation, University of Pretoria, Pretoria, viewed yymmdd < http://upetd.up.ac.za/thesis/available/etd-03062012-124912/ > en
dc.identifier.other F12/4/148/gm
dc.identifier.upetdurl http://upetd.up.ac.za/thesis/available/etd-03062012-124912/ en
dc.identifier.uri http://hdl.handle.net/2263/30660
dc.language.iso en
dc.publisher University of Pretoria en_ZA
dc.rights © 2012, University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. en
dc.subject UCTD en
dc.title A comparison of tax legislation of trusts between South Africa and the United States of America on emigration en
dc.type Dissertation en


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