Cases

This case is the first high court case dealing with the law on personal tax residence. I was successful. Inland Revenue has lodged an appeal to the Court of Appeal.

This case concerned a stallion breeding syndicate and the question of when the syndicate commenced its breeding business. It is the first case to consider the issue of when a breeding business commences.

This case is in practical terms the first legitimate expectation case to get home from the taxpayers' perspective.

This case concerns a number of interesting issues. Tax residency of a company, tax avoidance involving the Approved Issuer Levy (AIL) regime.

I successfully appeared for the Commissioner in this litigation. This is the first case concerning the residence of a company since the 1995 case of New Zealand Forest Product Finance Ltd NV v C of IR [1995] 2 NZLR 353.

This case involved a receiver recovering under an indeminity from the purchaser of a property in circumstances where the purchaser had failed to honour its obligations to pay the GST through the offset mechanism agreed.

This is a tax avoidance case concerning Optional Convertible Notes (OCNs)

This is the leading case on the question of whether the Commissioner is able to obtain general discovery in tax litigation when there has been an exchange of statements of position.

I appeared as lead counsel. This case represents the end of a dispute concerning the principle of security for costs being available to the Commissioner.

I appeared as lead counsel. This is the first case to deal with reassessment powers under the new disputes procedure.