Captain Morgan, a resident of South Africa, invested $$indirectly$$ outside South Africa in $$property$$ by purchasing $75\%$ of the equity share capital of Rickety Gin Ltd$,$ a foreign company that owns rent$-$producing properties. Rickety Gin Ltd was incorporated and formed in England. It has its place of effective management in England. All the properties are situated in England. Assume a tax rate of $15\%$ in England. Rickety Gin Ltd declared its after$-$tax return to its shareholders in the form of a dividend. Captain Morgan, therefore, receives his return from this investment in $$property$$ in the form of a foreign dividend. A foreign dividend of R$600000$ was received for the $2025$ year of assessment. REQUIRED: $5\mathrm{.}1$ Discuss if Rickety Gin Ltd can be defined as a controlled foreign company in relation to Captain Morgan in terms of section $9$D of the Income Tax Act. $$ State the requirements of section $9$D of the Income Tax Act, whereafter you apply the requirements to the facts of the scenario. $(6$ marks$)$ Communication skill: Clarity of expression $5\mathrm{.}2(1$ mark$)$ Discuss if the foreign dividend must be included in Captain Morgan$$s taxable income for the $2025$ year of assessment. $$ Assume that Rickety Gin Ltd is a controlled foreign company as defined. $(11$ marks$)$ Communication skill: Logical argument $5\mathrm{.}3(1$ mark$)$ Calculate the foreign tax rebate in terms of section $6$quat for Captain Morgan for the $2025$ year of assessment. $$ Assume the following for the $2025$ year of assessment, Captain Morgan had: o Taxable income of R$500000,$ o Normal tax liability of R$100000,$ and o Foreign taxable income of R$90000.(4$ marks$)$