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Rosa Turner $($aged $48$ and formerly a resident of the Republic$)$ emigrated to France on $1$ March $2017,$ after she was offered a lucrative employment contract in the field of medical research. Rosa is regarded to be ordinarily resident in France since her emigration. During the $2024$ year of assessment, Rosa took an extended leave of absence from work to spend a few months $(122$ days in total$)$ with her aging parents in Cape Town, South Africa. Prior to the $2024$ year of assessment, since her emigration, Rosa spent only the month of December $(31$ days$)$ each year in South Africa, visiting family and catching up with old friends. The following information relates to Rosa$$s receipts and accruals for the year of assessment ended $29$ February $2024($she is not considered to have any $$permanent establishment$$ as defined in section $1$ of the Income Tax Act, inside or outside the Republic$)$: A salary of R$2100000($Rand equivalent$)$ from her employment with Medsearch $($an institute for medical research, resident in France$).$ Rosa$$s research is based at the institute$$s main research laboratory situated in Paris. She signed her employment contract in South Africa, prior to her emigration; Gross rentals of R$600000$ from the letting of her former residence situated in Cape Town, South Africa; Gross dividends of R$22150$ from her shareholdings in South African companies listed on the Johannesburg Stock Exchange $($JSE$).$ None of these companies are regarded as a REIT or a controlled company, as defined; Dividends from foreign companies $($companies resident outside South Africa$)$ amounted to R$38650($Rand equivalent$)$ for the $2024$ year of assessment $$ Rosa does not hold at least $10\%$ of the total equity shares or voting rights in any of these companies Rosa holds a current account with Third National Bank $($a South African resident bank$),$ into which the rental income and South African dividend income is deposited. This account yielded interest of R$37300$ for the $2024$ year of assessment; Rosa$$s other current account, held with Bank of France $($a non$-$resident for South African tax purposes$),$ earned the Rand equivalent of R$51800$ in interest for the $2024$ year of assessment. Her monthly salary is deposited into this bank account. None of the funds in this account are utilised within the Republic. Rosa is considering selling her former residence in Cape Town. An estate agent has advised her that she should update the home by upgrading the interior finishes and adding in automated technological features as she could realise a much higher selling price. The estate agent is highly successful at selling homes to high profile buyers in the area and thinks that a modern, automated home meets the needs of such buyers. These updates would be quite costly but the agent is positive that Rosa will make a significant profit on the sale and more than recover her costs of the recommended improvements. a$.$ Discuss whether each of the amounts received by$/$accrued to Rosa for the $2024$ year of assessment must be included in her gross income for South African income tax purposes B$.$Discuss $($with reference to the relevant section in the Income Tax Act$)$ which amounts included in Rosa's gross income are regarded to be exempt from normal tax in South Africa. C$.$Advise Rosa whether she would be considered to have "crossed the Rubicon" if she follows the estate agent's advice $($assume that at the time of the sale, the $2024$ tax legislation remains unchanged$).$ Rosa has never disposed of any fixed property previously. You are not required to discuss any Capital Gains Tax consequences. Refer to the tax legislation and relevant case law in answering all parts of this question. Ignore withholding taxes and Value$-$Added Tax $($VAT$).$ You may assume that no Double Taxation Agreement exists between South Africa and France.

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