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Controlled foreign company (“CFC”) legislation, governed by section 9D of the Income Tax Act 58 of 1962, serves as anti‐avoidance legislation in South Africa’s residence‐based tax system. Section 9D provides for the calculation of a deemed amount which must be included in the South African resident’s income. This deemed amount is calculated with reference to the net income for the CFC’s foreign tax year. Section 9D(6) provides for this deemed amount, which is denominated in the foreign financial reporting currency, to be translated into South African rand by applying the average exchange rate for that year of assessment. The legislation refers to the South African resident’s year of assessment and not the CFC’s foreign tax year. It is submitted that the average exchange rate for the CFC’s foreign tax year should be used for translation. The author therefore disputes the period to be used in calculating the average exchange rate.

The health workforce of the 21st century has enormous challenges; health professionals need to be both experts in their field and equipped with leadership and managerial skills. These skills are not part of the regular curriculum, so specific programs bridging this gap are required. Since 2001, FAIMER®, with eight centers across the globe, has worked to create health professions education leaders through transformational learning experiences, developing a global community of practice encompassing over 40 countries. We describe the design, implementation, evaluation, and evolution of the leadership and management curriculum component of the global Institute over 15 years. The curriculum is developed and updated through practices that keep faculty and fellows connected, aligned, and learning together. The article highlights the unique features, challenges faced, and sustainability issues. With a robust mixed methods evaluation, there are substantial reasons to believe that the model works, is adaptable and replicable to meet local needs. The program is playing an important role of answering the call for training positive, strengths-based, collaborative leaders who are socially accountable and embrace the challenges for high quality equitable health care around the globe

The purpose of this study is to explore customer engagement (CE) in Facebook brand communities. It clusters Facebook brand fans to establish whether an existing typology holds in a diverse sample, and examines the differences in CE between the clusters. The predictive capabilities of CE on an important brand outcome, electronic word-of-mouth (eWOM), are determined.

In total, 493 respondents participated in an online survey. A two-step cluster analysis was conducted to determine the fan types. ANOVA was used to assess the differences in CE between the clusters. Multiple regression determined the predictive capabilities of CE on eWOM.

This research confirms the Facebook fan typology on a more diverse sample. Significant differences exist between the fan types on CE (captivation and gratification) and CE significantly predicts eWOM.

Future research could include motivations behind brand fan behavior. Using other CE measures may bring a different view. Theoretical perspectives other than social identity theory (SIT) may elicit other insights.

Insights into brand fan segments’ behavior and engagement allow brand managers to develop targeted marketing interactions. Gratification engagement is a stronger driver of eWOM, suggesting that brands should focus on marketing actions that will encourage gratification.

This research expands on Facebook brand fan typologies and explores CE as a multi-dimensional construct, rather than as a mere “like” action. Additionally, it determines the predictive capabilities of CE dimensions on eWOM. The findings suggest that SIT could be useful when examining CE in brand communities.

This chapter reviews successful pedagogical interventions in teaching literacy in languages of teaching and learning in the upper primary grades in low- and middle-income countries (LMICs) and explores how researchers and teachers decolonized classroom spaces to ensure student achievement of learning outcomes. Themes emerging from the analysis of data are biliteracy interventions, interventions in official and national languages, teacher professional development, and ecological interventions. Results of the review indicate that researchers decolonized classroom spaces by using student linguistic repertoires, evidence-based pedagogical strategies student cultural capital and engaging families and communities. The review also reveals that more research needs to be conducted on teaching and learning in upper primary grades. The linguistic diversity of LMICs provides rich contexts for more research in bilingual education and L2 acquisition which could be useful worldwide as stakeholders in the education process explore the best ways to improve learning outcomes in schools.

In the context of rapid change in higher education, there is a great demand for powerful theory and methods to address key issues, particularly related to teaching and learning. This chapter traces the uptake of Legitimation Code Theory (LCT) in higher education studies in South Africa to make sense of how and why this theory has become so popular. LCT draws on the works of Bernstein and Bourdieu to provide a powerful theoretical and analytical toolkit with which to analyse social practices. In the chapter, we argue that the attraction of this theory is that it attends to a ‘knowledge blindness’ whereby much higher education research, particularly that focussed on teaching and learning, fails to consider the nature and effects of the discipline or field being learned. The use of this theory is illustrated in the chapter by reference to a number of publications. In doing so, we illustrate the importance of conceptual tools that allow an interrogation of what we are teaching, who we are teaching and how this social practice takes place.

Recently researchers working on criminal behaviour have interested in elder offenders as the population is getting older. Crime statistics showed that the number of offenders over the age 55 is increasing each year. These statistics revealed that older people engage not only in minor crimes but also engage in serious crimes. One of this kind of crimes is sexual abuse which is defined as sexual offending against the individuals who are incapable of giving consent. Although public view regarding to elder people sexuality is seen as they are incapable of this kind of acts because of their age, the statistics showed that contrary. Yet the reasons behind the offending behaviour of these elderly people is explained little by the researchers. The aim of this chapter is to review the psychological perspective including neurobiological, psychiatric, cognitive and behavioural perspective. Neurobiological and psychiatric approach mainly focused on disease that lead to criminal conduct like dementia or paedophilia. Cognitive approach emphasises the cognitive distortions regarding to sexual abuse behaviour. Behavioural approach proposed that the learning process based on classical conditioning and operant conditioning determine the sexual abuse behaviour. Yet none of the theories alone not enough to explain the sexual abuse behaviour in elderly people. There is a need for more studies on sex offending behaviour of elderly people in order to have comprehensive understanding of their behaviour and to put forward new theoretical models.

In an attempt to enhance the core professional values of tax practitioners in South Africa, the South African Revenue Service has proposed the regulation of tax practitioners’ services. It is arguable whether or not this would be the only factor to influence the ethical behaviour of tax practitioners. A literature review was conducted to identify factors that could influence the ethical behaviour of tax practitioners. Numerous possibilities emerged. It is therefore recommended that if regulation is to be successful, caution should be exercised in writing a code of best practice for tax practitioners.