Page 77 - Gross Income class slides
P. 77
GROSS INCOME
Capital
• Capital vs. Income
• Difficult to determine because subjective
• Tree vs fruit (Visser)
• Fixed (acquired to keep) vs floating (acquired to sell/normal trade)
capital
• Investment vs speculation (Lace Proprietary Mines)
• Golden Rule: Intention of the taxpayer
• Proceeds will be INCOME if asset acquired with the intention
of selling it at a profit (“scheme of profit-making”)
• Proceeds will be CAPITAL if asset acquired and held with the
intention of earning income from that asset e.g. rent, interest
or dividends
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