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GROSS INCOME - Coggle Diagram
GROSS INCOME
of a capital nature
nature of the ‘asset’
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3.
Kruger Rand normally seen as capital in nature, unless in trade to buy and sell.
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mixed or dual intention
1.
Consider the taxpayer’s dominant intention. The fact that the asset is sold at a profit, does not necessarily indicate a change of intention.
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change of intention
1.
The mere decision to sell an asset does not change an intention. A capital asset may be realised at its best advantage.
2.
Must be careful to not “cross the Rubicon” and embark on a scheme of profit making. This indicate a change of intention and the proceeds being revenue in nature.
3.
The secondary purpose could taint the primary purpose of a taxpayer, if a taxpayer’s actions become too frequency.
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Received by
Received by him, on his own behalf, for his own benefit.
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Deposits are still received and form part of gross income.
Only not received if kept in a separate in trust account for the benefit of the customer.
Gift card receipts are ‘received’ by the taxpayer, but not for the taxpayers own benefit
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(i) in the case of any resident, the total amount, in cash or otherwise, received by or accrued
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Total Amount
The test is objective and not subjective and arm’s length principles of valuation must be applied in each case.
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in relation to any year or period of assessment, means-