Although donations by foreigners are not taxable, the settlement that Van der Merwe reached with Sars has now seen the money being classified as “other income”.
I know you're quoting an article, but this is wrong. Donations from non-residents (for tax purposes) are not taxable. Being a foreigner has nothing to do with it. While it's true that most foreigners are not South African tax residents, technically the taxation of the donation depends on the tax-residency of the person making the donation, not their citizenship.