insights
What’s in a coin?
With Bitcoin hitting the $100k milestone this month, it's an opportune time to examine the U.S. income tax treatment of virtual currencies. The U.S. tax principles regarding virtual currencies have...
New Zealand to review FIF rules
This week Inland Revenue released official's issues paper, "Effect of the FIF rules on immigration: proposals for amendments". Inland Revenue acknowledges the impact of the foreign investment fund...
Section 250 deduction for GILTI
Following on from Excess Profits and GILTI, we will now look into the Section 250 deduction. Section 250 applies to tax years beginning on or after January 1, 2018. Until 31 December 2025, the...
Excess profits taxes and U.S. GILTI
‘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,...
IRS announces significant revenue milestone – 1.3 billion in tax revenue collected through its High Income, Non-Filer campaign
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...
Let’s take a deep dive into KiwiSaver
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....
Transactions with Foreign Trusts and Receipt of Foreign Gifts
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...
Let’s take a deep dive into Passive Foreign Investment Companies (PFICs)
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...
Paying it Forwards with Trees That Count: From One Nelson Native to Another
In December last year, NZ US Tax Specialists Limited funded 175 native trees for planting through Trees That Count. We were contacted last month and informed that the Nelson Forest and Bird Society...
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