Following the 2015 tax residency case CIR v Diamond, which went to the Court of Appeal, Inland Revenue has updated its tests for NZ tax residency through the issue of Interpretation Statement IS 16/03, issued 21 September 2016. IS 16/03 supersedes IS 14/01, issued in...
Following an officials’ issues paper released by the Inland Revenue Department in May this year, an updated consultation paper on the New Zealand tax treatment of Employee Share Schemes (ESS) was issued earlier this month. Revision of the New Zealand tax...
Last week the New Zealand government issued a discussion document proposing that the Organization for Economic Co-operation and Development (OECD)’s recommendations contained in the Base Erosion Profit Shifting (BEPS) plan for combating hybrid mismatches be...
The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill (‘bill’) was recently introduced in New Zealand. The bill contains a number of proposed amendments to the Income Tax Act and the Tax Administration Act. From an international...
The IRS has announced it will tighten its anti-inversion rules in Notice 2015-79, issued last week, through regulations which will address tax avoidance transactions at the time of, and post-inversion. Internal Revenue Code section 7874 (Rules Relating To Expatriated...
The 2015 annual report was presented to the IRS Commissioner yesterday. The report consists of four sections: 1. General report, addressing the following: Issue one: The IRS needs sufficient funding to operate efficiently and effectively, provide timely and useful...
