Controlled foreign company regimes are sets of anti-avoidance rules. These regimes assist in preventing companies from diverting income through tax havens. Such regimes require the parent company to report the income of its subsidiary for New Zealand tax purposes as if it were its own. Complying...

Governments attack tax avoidance in a number of ways. Statutory anti-avoidance rules are one means. Such rules come in two forms: specific and general. General rules potentially apply to any kind of transaction that may result in tax avoidance. Section 99 of the New Zealand income Tax Act 1976...

Much of the world's tax treaty policy is driven by approaches that suit, or that have suited, the USA. Changes to the relevant economic positions of the USA and the rest of the world have seen an altering of the way in which treaties are negotiated. At the time of writing the effect of these...

This income tax textbook focuses primarily on the basic questions of income tax law. These include the interpretation of tax statutes, the concept of income, the distinction between capital and revenue, deductibility of expenditure, tax accounting, and international tax issues such as source,...

Major tax reforms in the 1980s saw movement towards to tax systems that are relatively pure, in that they are not given additional tasks promoting economic or social policies. The USA under the Clinton Administration began to show signs of reversing some of the changes of the 1980s. Tax policy...

Legislation regulating tax preparers has seen little attention in New Zealand, but this is not the case in Australia and the USA. In Australia is obligatory for those who professionally prepare tax returns to be registered as tax agents. In both countries – the USA and Australia – tax...

During the 1980s a major thrust of the European Community (now the European Union) effort and policy was towards the creation of a single market by the early 1990s. Issues that were most important regarding tax law were that of mergers and parent and subsidiaries. The harmonisation process is...

Tax simplification is a subject that causes great debate throughout the OECD. The general basis for simplification programmes is to identify factors that cause taxation to be complex, followed by an attempt to minimise the effects of these factors. Through the 1980s New Zealand engaged in one of...

Section 67 of the Income Tax Act 1976 taxes as income certain gains on the sale of land that would ordinarily be classed as capital. Several proposals were made to repeal the section or severely to limit its effect. The article argues that the section contains a number of flaws, though none that...

New Zealand has concluded double tax agreements with 24 countries. Double tax conventions are brought into effect by Orders in Council, a form of subordinate legislation. They are also incorporated in legislation by reference under section 294 of the New Zealand Income Tax Act 1976, which states...