A taxpayer with just enough passing acquaintance with tax legislation to be dangerous had a bright idea in relation to the primary residence exclusion in the Eighth Schedule to the Income Tax Act. Having read five years ago that the first R2 million of a gain on disposal of your primary residence is excluded from

In Capstone 556 (Pty) Ltd v CSARS [2014] 77 SATC 1 WC the Western Cape High Court heard an appeal from the decision of the tax court. In issue were: the nature of the proceeds of a disposal of shares; the deductibility of a so-called “equity kicker” by the taxpayer; and how to treat an