Professional Certificate Programme

Professional Certificate in Tax Opinion & Dispute Writing

  • Lectures 0
  • Modules 3
  • Duration 6 months
  • Language English
  • Reviews (5)

Description

This professional certificate programme covers the areas of tax research, opinion and dispute writing. The purpose of this SLP programme is to develop the critical research, problem solving and writing skills to draft TAA compliant tax opinions that will mitigate SARS penalty risk. The course will also equip participants with the skill to effectively respond to SARS letter of audit findings, prepare technical sound SARS objections and appeals.


Course Format & Programme

The course induction is scheduled for 9 January 2019.

The technical component of the course is divided into three modules: 

1.    Principles of tax research;

2.    Tax advisory opinions; and

3.    Tax dispute / controversy. 

Each module will commence with a lecture and three practical assignments. Topics for assignments will be provided to course participants.

In addition, three Webinars will be presented in “live-seminar” format. Assignments will be issued electronically, supplemented by Webinar feedback sessions.


Applications & Admission Requirements

Minimum academic requirement:
    -    B.Com, or

    -    LL.B degree

Minimum work experience:
    -    5 years unstructured work experience, or

    -    3 years articles or learnership


Assessment & Award of Certificate

Successful completion of the course requires average mark of 50% for all assignments.

Upon completion, successful candidates will receive a Certificate from The Tax Faculty.


What you will learn

Module 1:  Fundamentals of tax research 

The first module is be dedicated to the fundamentals associated with tax research. 

Successful tax professionals need to understand the various sources for research as generated by the various arms of government, such as National Treasury (tax legislation and policy), SARS (interpretation and administration) and case law.

Academic and international research will also be considered for supplementary consideration. The lecture pertaining to this part of the course will be followed by practical assignments.

The first assignment will involve introductory research questions and answers that can be readily obtained from various sources.
The second assignment will require a short memorandum describing the nature of law and interpretation related to issues/problems with less precise solutions and outcomes.

The third assignment will focus on issues with useful indicators that can best be found in local tax legislative history.


Module 2:  Tax opinions: Developing a position & principles of opinion writing 

The second part of the course will be dedicated to opinion writing.  Course participants will learn how to write in terms of assessing risk as opposed to definitive conclusions.  This part of the course will include discussions pertaining to the role of opinions in terms of penalties (e.g. section 223 opinions).  The lecture will also cover general recurring doctrines (e.g. application of the general anti-avoidance rule and the substance-over-form).  The lecture pertaining to this part will be followed by assignments involving practical opinion writing.

The first assignment will entail the writing of an opinion associated with a tax return. Students will be requested to assess the risk associated with the position as well as whether an accounting provision will be required for financial purposes.

The second assignment will be associated with an advisory opinion in terms of setting up a proposed structure.  Course participants will be expected to assess various technical risks and outcome probabilities.

The third assignment will be associated with the steps involving a series of transactions.  The trainee will be expected to prepare a step memorandum as well as an opinion detailing key risks.  This assignment will include considerations relating to anti-avoidance doctrines. 

 

Module 3:  Controversy writing

The third part of the course will be dedicated to the initial stages of taxpayer-SARS controversy. 

This process starts with the phase of initial queries and responses. These queries and responses often escalate in assessments, objections and appeals.  Writing of this nature is as much about procedure as about substance. Both the relevant portions of the Tax Administration Act and the Promotion of Administrative Justice Act will be considered.  The lecture to this final part will be followed by assignments relating to the various documents arising during the initial stages of tax controversy.

The first assignment will entail the writing of a response to a SARS information request and the review of a related document of SARS findings.  Trainees are expected to analyse information available for appropriate disclosure while protecting taxpayer rights.
The second assignment will entail the writing of an objection to a SARS assessment as well as a corresponding request for suspension of payment.  Trainees are expected to defend the taxpayer’s position in terms of substance and process.

The third assignment will entail the writing of an appeal along with a side memorandum providing advice as to a reasonable compromise based on a probable outcome of risks.  Students are expected to best argue the taxpayer’s position but also retain the ability to best advise the client on whether to compromise based on the taxpayer’s likelihood of success.

 

 

 


Flexible payment options

Payment Option 1: Once-off Payment

Course Investment: R13 950.00 (incl. VAT)

SAIT member discount

Members in good standing qualify for R2 000.00 discount (Apply discount code SAIT_TR during check-out.)

Payment option 2: Payment Plan (Debit Order)
SAIT members

Instalments: R2 000.00 
Deposit payable upon registration: R3 950.00

Other professional members

Instalments: R2 000.00 
Deposit payable upon registration: R3 950.00

Payment option 3: Study Loan
Download the study loan application form here. 


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Curriculum

Instructors

Prof. Keith  Engel
Prof. Keith Engel
Keith is the Chief Executive of SA Institute of Ta...

Reviews

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4 Ratings

Detailed Ratings

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    The Online Etymology Dictionary explains that the origin of job is from the obsolete phrase jobbe of work in the sense of piece of work, and most dictionaries list the Middle English gobbe meaning lump (gob) as the origin of jobbe. Attempts to link the word to the biblical character Job seem to be folk etymology.

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    The Online Etymology Dictionary explains that the origin of job is from the obsolete phrase jobbe of work in the sense of piece of work, and most dictionaries list the Middle English gobbe meaning lump (gob) as the origin of jobbe. Attempts to link the word to the biblical character Job seem to be folk etymology.

    • alt

      The Online Etymology Dictionary explains that the origin of job is from the obsolete phrase jobbe of work in the sense of piece of work, and most dictionaries list.

    • alt

      The Online Etymology Dictionary explains that the origin of job is from the obsolete phrase jobbe of work in the sense of piece of work, and most dictionaries list.

  • alt

    The Online Etymology Dictionary explains that the origin of job is from the obsolete phrase jobbe of work in the sense of piece of work, and most dictionaries list the Middle English gobbe meaning lump (gob) as the origin of jobbe. Attempts to link the word to the biblical character Job seem to be folk etymology.