Presumption Rules – Grantor Trusts

The discretionary trust has traditionally been a popular entity to form in New Zealand for a variety of reasons, including asset protection and estate planning. A discretionary trust provides the trustees of the trust with discretionary powers to make decisions that...

FATCA update – Reporting Domestic Entities

FATCA update: Today the Internal Revenue Service issued advice that reporting by specified domestic United States entities of specified foreign financial assets will not be required for taxable years beginning any earlier than 31 December 2012. A ‘specified...

Covered Expatriates & Expatriation from the US

If you are thinking about expatriating, beware of taxation under Section 877 and 877A of the Internal Revenue Code – Expatriation to avoid tax, and tax responsibilities of expatriation.   Covered expatriates are subject to specific taxing mechanisms under...

LTC – New Loss Limitation Rules

It is very interesting to observe the new loss limitation rules under the New Zealand Look Through Company (LTC) regime recently introduced which seems to have created more problems than it might have solved. The New Zealand Institute of Chartered Accountants’...

Return preparers – professional obligations

The professional conduct of paid US tax return preparers is heavily regulated under the Internal Revenue Code. It is timely to note that return preparers cannot, under any circumstances, negotiate or cash a taxpayer’s tax refund check. Even authorization to...