This article examines two broad areas of capital gains tax (CGT) design in respect of the taxation of non-residents. The first area relates to the domestic design of the tax and focuses on whether a CGT should apply to all assets held by non-residents or to some limited subset of those assets...

Virgin Holding SA v. Commissioner of Taxation was a decision in the Federal Court of Australia in late 2008. It concerned a very important issue in the interpretation of the Australia-Swiss double taxation conventions. This was whether the term "income tax" included tax on capital gains. The...

This article tries to find a new way through old arguments about whether or not New Zealand should have a realization-based capital gains tax. Instead of revisiting the first-principles analysis of the costs and benefits of a capital gains tax, it starts by observing that many countries have...

This article reviews the case for taxing capital gains in New Zealand. The analogy is drawn between a taxation system and a medieval toll bridge. The wider the span of the bridge the more traffic can pass in the same time period. This can allow a reduction in the rate of toll, reducing the...