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There is no doubt that the tax laws of many countries are complex and difficult to comply with administratively. In particular, Australia, New Zealand and the United States have tax systems that are generally recognized as complex especially for small businesses. They also have the distinction...
Persistent link: https://www.econbiz.de/10013036154
This paper argues that there is too great a reliance placed on anti-avoidance provisions, discretions reposed in the revenue, and judicially developed doctrines as a means of countering tax avoidance. In view of the difficulties in defining and countering tax avoidance, it is suggested that...
Persistent link: https://www.econbiz.de/10013036510
The trust is the most useful device that New Zealand offers to non-residents in the field of international tax planning. So long as settlors, beneficiaries, and income are all foreign the trust is unlikely to attract New Zealand tax. The residence of the trustee has no effect on the tax benefits...
Persistent link: https://www.econbiz.de/10014195277
Sections 226 to 233 of the New Zealand Income Tax Act 1976 contain a special regime for the taxation of trusts. Income that is distributed by the trustee is taxed in the hands of the beneficiary, and income that is accumulate is taxed in the hands of the trustee. The regime contains a number of...
Persistent link: https://www.econbiz.de/10014195937
At a time when we are witnessing globalized competition to attract the best and brightest students into law and business schools, a qualitative investigation into legal teaching methods to diverse student cohorts is most relevant. This article makes a comparison across the unique educational...
Persistent link: https://www.econbiz.de/10012967598
Persistent link: https://www.econbiz.de/10014273498
In the latter half of the 1980s the tax climate in Australia and New Zealand changed markedly. While throughout the world there were major tax reforms, the changes in Australasia were more fundamental, and both structural and radical. Major changes that were adopted in one or both of the two...
Persistent link: https://www.econbiz.de/10013133720
This article considers the issue of whether or not New Zealand trustees must be recognized as valid parties in New Zealand's treaty network by exploring the various approaches that may be adopted in the interpretation of tax treaties and the diverging constructions of the residence article.New...
Persistent link: https://www.econbiz.de/10013108472
This article examines the potential conflict between thin capitalization rules and the OECD Model article on non-discrimination using the New Zealand regime exempli gratia. It is discriminatory to impose a higher tax burden on an enterprise funded with foreign capital. Yet that is the basis for...
Persistent link: https://www.econbiz.de/10013090536