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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.