‘Excess profits taxes’ is not a term that is frequently heard here in NZ. This is unlike the term ‘capital gains tax’, which has been a longstanding political football for the country. This week, however, we heard the term in the news after a long hiatus, as...
By Gina Gatchell, Director “During the previous administration, as audit rates on high-income taxpayers fell, the share of audits on taxpayers with incomes under $200,000 increased,” Yellen said in remarks to be delivered at an IRS service center in...
Many countries develop and manage their tax policies to influence socio-economic behaviour. N.Z. is one such example. N.Z. has traditionally been slow to prepare its inhabitants for retirement. Other countries have had compulsory superannuation for decades, such as...
By Gina Gatchell, Director The U.S. Treasury Department and the Internal Revenue Service have issued proposed regulations concerning Sections 643(i), 679, 6039F, 6048 and 6677 of the Internal Revenue Code. These relate to transactions between U.S. persons and non-U.S....
The PFIC regime has been in existence since 1986. Introduced in the Tax Reform Act, the regime closed a loophole. Prior to the change, assets could be transferred to entities organized outside the U.S., in order to escape U.S. taxation. As with other foreign...
