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ANZCO Foods Limited v CIR
This is the High Court judgement in the recent ANZCO litigation. It concerns depreciable intangible property and what constitutes a right to use land.
Ben Nevis Forestry Ventures Limited v CIR
This is the first case on tax avoidance to be heard by the Supreme Court. The party I represented was successful.
NRWT Changes Mooted by IRD Officials
In May 2015 officials released an issues paper with respect to New Zealand’s non-resident withholding tax (NRWT) rules. The paper proposes changes to deal with perceived deficiencies in the rules particularly with respect to related party cross-border transactions.
Taxation of complex employment remuneration
This article explores the exposure draft released by Inland Revenue relating to the taxation of employee’s remuneration in complex remuneration situations.
The position of victims of fraud
This article looks at the case of HC Services Ltd v Commissioner of Inland Revenue [2014] NZHC 1169, (2014) 26 NZTC 21,071. The case exposes a conceptual error in the legal logic of the taxpayer’s case and sets out clearly the relationship fraud has to the creation of legal rights and obligations generally and the application of the general anti-avoidance provision in particular. The article explores the options of the victim.
BEP and Tax Avoidance - Government looks for more revenue
This article looks at the international developments seeking to address the erosion of the tax base and at other moves being made by Government to increase revenue.
Tax and Crime
This article looks at the issues surrounding defense of allegations of tax crimes by Inland Revenue and how allegations of tax crimes intersect with civil recovery actions and the proceeds of crime Act.
Black Hole Expenditure
This article looks at the issue of black hole expenditure and asks whether the latest moves by Government effectively address the issue.
How to purchase copies of James Coleman’s text book, Tax Avoidance Law in New Zealand
Copies of this text book can be acquired over the internet from CCH by clicking here[http://www.cch.co.nz/nz/onlinestore/ProductDetails.aspx?PageTitle=Tax-Avoidance-Law-in-New-Zealand-Edition-2&ProductID=10461]
Is there an arguable common law basis for accountants privilege?
This article looks at the English Supreme Court decision in R (on the application of Prudential Plc) v Special Commissioner of Income Tax) [2013] UKSC 1. The case involved an argument that the advice of accountants ought to enjoy a form of common law privilege independent of statute. The case was lost but largely due to a marked Judicial reluctance to do anything new rather than because the argument was unsound on a first principles basis.