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...
The jurisdictions of New Zealand and the United States of America have very different tax regimes. However, there is a common theme which we, as tax practitioners experience, year in and year out. That common theme is the complex anti-deferral and anti-avoidance...
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...
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...
The 2022 filing season finished yesterday, 17 October 2022. Below are some statistics from this year’s filing season. These provide insight into the IRS’ processing of U.S. federal income tax returns through the 2022 season. Data is from the midyear report...
