Revised FIF rules edged closer to enactment with the passing of the Taxation (Annual Rates for 2025–26, Compliance Simplification, and Remedial Measures) Bill on 26 August 2025 – Part One: Extended Revenue Account Method (‘extended RAM’)

by Gina Gatchell | Sep 26, 2025 | Articles

Introduction and Scope

N.Z.’s foreign investment fund regime is complex and is becoming increasingly so. Therefore, this article is being published in three parts.

Part One of this article addresses:

U.S. citizens and green card holders,
who became tax residents of N.Z. on or after 1 April 2024 and,
are taxable on worldwide income in N.Z. (full N.Z. tax residents), and,
are not transitional residents, and,
have portfolio interests[1] in foreign shares.

Part Two of this article will address non-U.S. citizens and others who do not have a green card at the time at which they are subject to N.Z. income tax on worldwide income.

Part Three of this article will address the interrelationship between RAM and extended RAM, and various other situations involving disposals.

Part One: Extended Revenue Account Method (‘Extended RAM’) – new rules for U.S. citizens and green card holders

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