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The Government is Tightening up the Rules on Regularly Buying and Selling Land.
The tax bill just introduced to Parliament is billed by the Government as pro-economic recovery and it is in lots of ways it is. But snuck into the bill are, however, some moves that have nothing to do with economic recovery.
Residence Disputes under DTA tie-breaker provisions
Anyone who has been involved in the Mutual Agreement procedure found in our DTA’s will know that the process does not always produce an outcome. When that happens, one still has to litigate the issue with Inland Revenue.
Analysis of multi-party contracts for GST
Frequently, when analysing cross border GST situations, there are multi-party contracts involved. That can complicate the analysis. This article looks at the three common types of multi-party contractual arrangements.
Inbound Migration Traps
There are some overseas investment products that fall within the category of a foreign life insurance entitlement but also meet the definition of a foreign superannuation scheme. This is problematic.
IRD interpretation statements and their examples?
Most tax lawyers my age will remember Prof John Prebble QC's book The Taxation of Property Transactions. It was the go-to book whenever an issue arose involving the sale of land or property. Nowadays we tend to look at Inland Revenue Interpretation Statements.
Tax Issues with Liquidation Start and End Dates
Today Inland Revenue issued an exposure draft on the topic of when a particular form of liquidation starts. Inland Revenue said that in the case of long-form liquidations, it is when the liquidator is appointed. The start point for liquidations is relevant to the application of s CD 26, which excludes capital distributions on liquidation from the concept of a dividend.
Tax Crime
Section 143B(1)(b) and (f) of the Tax Administration Act 1994 are unusual provisions in that they have an either or wording to the charge. For example section 143B(1) begins by saying that a person commits an offence against this Act if the person-
CIR v Chand
This is the first case dealing with the sentencing approach when a defendant has pleaded guilty to evading assessment rather than evading payment of tax under s 143B(1)(f) of the TAA
Additional Support for Covid Affected Businesses
Information about the government Covid-19 resurgence support payments can be found at: