Critics of draft capital gains tax rules in South Africa say the proposals will lead to double taxation when companies pursue corporate restructuring. But US Treasury official Keith Engel, who is advising the South African government on its tax reforms, assures critics the impact of taxes on restructurings will not be disregarded. He proposes special company restructuring rules that "would facilitate company formations, reorganizations and unbundlings among listed companies, as well as internal group realignments". He said: "Special rules would also apply to ensure this relief could not be used as a tax-free mechanism to expatriate internally-generated profits from South African soil."