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Weekly Comments 2015, 2014, 2013 & 2012 Index

Administration costs

• Company administration costs 2014 amendments
• Interpretation Statement IS 14/04

Amalgamations:

• ASC of an amalgamated company

Amendment Acts:

• Taxation (Annual Rates, Returns Filing, and Remedial Matters) Act 2012: income tax amendments
• Taxation (Annual Rates, Returns Filing, and Remedial Matters) Act 2012: GST amendments
• Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Act 2013: various income tax amendments
• Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Act 2013: GST on mixed use assets
• Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Act 2013: GST and non-residents
• Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Act 2013: other GST amendments
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Black hole expenditure amendments
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Company administration costs
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Deregistered charities
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Financial arrangements - Foreign ASAPs
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: GST changes to apportionment rules and land transactions rules
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: GST miscellaneous amendments
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Lease inducements, surrenders and leases on land
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Thin capitalisation - non-resident shareholders acting together
• Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014: Thin capitalisation - extended application to trusts

Assessments:

• Exposure draft on SPS Requests to amend assessments

Associated persons:

• TRA 02/10 [2015] NZTRA 01 when 2 companies are associated for GST
• Association for GST: Concepts 124 Ltd - companies associated through control by a corporate trustee
• Input tax restrictions on supplies between associated persons: TRA 008/14, [2014] NZTRA 15

Australian tax:

• Trust beneficiary income

Avoidance:

• Abusive tax position QWBA
• Alesco Court of Appeal case
• BNZ avoidance case
• Tax avoidance scenarios (draft QWBA - early version)
• Tax avoidance scenarios (June 2015 draft QWBA)
• Tax avoidance and debt capitalisation
• TRA 001/13 [2014] dividend stripping case
• Westpac avoidance case

Bad debts:

• Bad debts deductions amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee

Base erosion and profit shifting (BEPS):

• BEPS measures in November 2013 Tax Policy Work Programme

Black hole expenditure:

• Black hole amendments proposed in Employee Allowances Tax Bill
• Black hole resource consents amendments proposed in Employee Allowances Tax Bill
• Black hole expenditure amendments enacted
• Budget initiatives 2014 - black hole R&D
• Company administration costs amendments

CFCs:

• CFCs new income calculation rules

Charities:

• Auditing requirements for charities
• Charities registration board
• De-registering charities IP
• De-registering charities - timing rules
• De-registering charities - how new rules apply and effect on donees status
• Greenpeace de-registration Court of Appeal case
• Charities and political purpose - Greenpeace Supreme Court case case

Debt remission:

• Debt remission between related parties - proposals in IP
• When debt remission income could arise - IP
• Tax avoidance and debt capitalisation - QWBA

Deductions:

• Bad debt deductions amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Borrowing expenses DB 5 BR Pub
• Companion's travel expenses
• Expenditure on land not part of a business
• LTCs interest deductibility QWBAs
• Management fees paid by a trust
• Mixed-use assets
• Notional interest under IFRS amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Resource consents
• Retention money

Depreciation:

• Commercial fit-out
• R&M Expenditure IS
• Earthquake relief measures
• Earthquake relief measures Part 2
• QWBA: Depreciation roll-over relief
• Earthquake relief additional amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill SOP

Discussion documents:

• Black hole R&D expenditure DD
• Bodies corporate - GST treatment Discussion Document

Earthquake relief:

• Earthquake relief measures
• Earthquake relief measures Part 2
• QWBA: Depreciation roll-over relief
• Earthquake relief additional amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill SOP
• Earthquake relief additional amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill SOP
• Earthquake relief comprehensive PDF attachment

Employee allowances:

• Employee allowances IP (accommodation)
• Employee allowances IP (meals etc.)

Employee share schemes:

• Employee share schemes - current rules
• Employee share schemes IP

FBT:

• FBT - Benefits provided by third parties BR Pub 14/10
• FBT on carparks withdrawn - not enacted
• FBT - Exclusion for car parks provided on an employer's premises - draft ruling
• FBT – Exclusion for car parks provided on the premises of a company in same group as employer - draft ruling
• Insurance: sickness and accident insurance taken by employee and employer pays premiums - draft QWBA
• Insurance: sickness and accident insurance taken by employer for employee - draft QWBA
• Insurance: term life insurance taken by employee and employer pays premiums - QB 15/05
• Insurance: term life insurance taken by employer for employee - QB 15/06
• Short term charge facilities amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill

FIFs:

• Attributed FIF Income Method for FIFs
• Choices between methods for FIFs
• Disclosures for FIFs
• Entry and exit rules for FIFs
• Exemptions from the FIF tax regime
• FIF superannuation interests
• FIF superannuation interests amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign dividend rules for FIFs
• Foreign superannuation tax IP
• Imputation credits on FIF income amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Life insurance FIFs
• Losses from FIFs
• Methods for calculating FIF income
• New FIF income calculation rules
• Paper on FIFs - fully updated
• Presentation on FIF rules 20 April 2012

Financial arrangements:

• FA tax case: Sovereign
• Foreign ASAPs - IFRS Taxpayers
• Foreign ASAPs - Non-IFRS Taxpayers
• Foreign ASAPs (12—month ASAPs) - Non-IFRS Taxpayers
• Interpretation of financial arrangements rules - Sovereign Assurance Court of Appeal decision
• S&P Agreements IP
• Short term agreements as financial arrangements amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• Short term agreements as financial arrangements amendments in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014

Financial reporting requirements:

• Financial reporting requirements amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee

Foreign tax credits:

• Foreign tax credits draft IS

Foreign superannuation withdrawals:

• Foreign superannuation withdrawals tax inclusions and exclusions amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax assessable period and formula method amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax schedule method and KiwiSaver withdrawals amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax inclusions and exclusions amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals assessable period amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• FIF superannuation interests amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals KiwiSaver withdrawals amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals Schedule method and formula method amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• 15% temporary amnesty in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• 15% temporary amnesty extension in SOP to Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee

Government budgets:

• Budget 2012
• Budget initiatives 2014 - black hole R&D
• Budget initiatives 2014 - cashing out R&D tax losses
• Budget initiatives 2015 - property compliance proposals

GST:

• Association for GST: Concepts 124 Ltd - companies associated through control by a corporate trustee
• Apportionment rules and zero-rating of land rules amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• GST changes to apportionment rules and land transactions rules in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014
• Whether a binding contract always establishes a transaction giving rise to a supply for GST purposes
• Whether agreement became binding before or after GST rate increase: TRA 023/12 [2014] NZTRA 10
• Bodies corporate - GST treatment Discussion Document
• Bodies corporate GST - Commissioner's interim operational position
• Bodies corporate - GST registration: Public rulings IP
• Body Corporate 358851 - GST: product ruling
• GST on body corporates amendments in Taxation (Annual Rates for 2015-16, Research and Development, and Remedial Matters) Bill as first introduced
• Coastal permits and certificates of compliance – Secondhand goods input tax deduction — draft ruling
• Compulsory acquisition of land: QWBA
• GST - Directors' fees - draft
• Fishing quota – Secondhand goods input tax deductions - draft ruling
• GST cases – Qantas
• GST cases – Thompson
• GST cases - groups other than companies TRA 021/12 [2013] NZTRA 11
• GST cases - when 2 companies are associated TRA 02/10 [2015] NZTRA 01
• GST cases – ID Tours - GST on advisory tourism services
• GST cases – Wyatt v Real estate Agents' Authority
• GST groups – groups of entities other than companies
• GST groups – QB 07/03 Trustees of multiple trusts
• Hire firm security bonds - GST: QWBA
• Immigration services IS
• Immigration services IP
• Input tax restrictions on supplies between associated persons: TRA 008/14, [2014] NZTRA 15
• Late return charges (including library fines and parking fines - GST: QWBA
• Legal services to non-residents on land transactions - GST - draft ruling
ruling
• Lotteries, raffles, sweepstakes and prize competitions - GST: QWBA
• Matrimonial property agreements - GST: IRD Statement
• Mixed-use assets GST
• GST Miscellaneous amendments in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Act 2014
• GST on costs of mortgagee sales - exposure draft of operational statement
• Non-profit bodies - Registration, accounting for GST - draft QWBA
• Non-residents GST registration (rules as introduced)
• Non-residents GST registration (rules as enacted)
• Recent developments in GST to December 2014
• Remedial issues IP
• Remedial issues amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Retirement villages - GST treatment - draft IS
• State schools - Payments by parents or guardians of students - GST treatment
• Transfer of an interest in a partnership - draft QWBA
• Transfer of an interest in a partnership - final QWBA
• GST amendments in Taxation (Annual Rates, Returns Filing, and Remedial Matters) Act 2012
• GST amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• GST amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Act 2013

Imputation credits:

• Imputation credits on Australian dividends amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee

IRD Commissioner's operational statements:

• Bodies corporate GST - Commissioner's interim operational position
• GST on costs of mortgagee sales - exposure draft of operational statement
• What is significant expenditure in a major development or division - Commissioner's operational position
• Tax residence - transitional operational position

IRD Fact Sheets:

• Black Hole R&D Fact Sheet - 2014 Budget

IRD Issues Papers:

• Bright-line test IP
• Debt remission between related parties - proposals in IP
• De-registering charities IP
• Employee allowances IP (accommodation)
• Employee allowances IP (meals etc.)
• Employee share schemes IP
• Financial arrangements: S&P agreements IP
• Foreign superannuation taxation IP
• GST on immigration services IP
• GST remedial issues IP
• Land acquisition date IP
• Land related lease payments IP
• NRWT: proposed changes affecting related party and branch lending IP (defining income for NRWT)
• NRWT: proposed changes affecting related party and branch lending (restricting AIL and branch exemptions)
• R&D tax losses IP: current rules
• R&D tax losses IP: proposed new rules
• Salary trade-offs as income IP
• Thin capitalisation IP
• Thin capitalisation technical issues

IRD Interpretation Statements:

• Company administration costs - IS 14/04
• Foreign tax credits draft IS
• GST and immigration services IS
• Repairs & maintenance expenditure IS
• Residence draft IS: natural persons
• Residence draft IS: companies and trusts
• Residence IS 14/01 - natural persons
• Residence IS 14/01 - corporates
• Retirement villages - GST treatment - draft IS
• Share transfers timing IS
• Whether rights under Companies Act 1993 give rise to a shareholder decision-making right IS
• Trust beneficiary income vs tax beneficiary income IS

IRD Product Rulings:

• Body Corporate 358851 - GST

IRD Public Binding Rulings:

• Borrowing expenses DB 5 BR Pub
• FBT - Benefits provided by third parties BR Pub 14/10
• FBT - Exclusion for car parks provided on an employer's premises - draft ruling
• FBT – Exclusion for car parks provided on the premises of a company in same group as employer - draft ruling
• GST – Coastal permits and certificates of compliance – Secondhand goods input tax deduction - draft ruling
• GST – Directors' fees - draft ruling
• GST – Fishing quota – Secondhand goods input tax deductions - draft ruling
• GST – Legal services to non-residents on land transactions - draft ruling
• GST – Payments by parents or guardians of students to state schools
• Subdivision of shares BR Pub
• Trusts – Whether a beneficiary will be treated as a settlor where there is no loan - draft ruling
• Trusts – Whether a beneficiary will be treated as a settlor where there is a loan - draft ruling
• Unclaimed amounts of $100 or less BR Pub

IRD Public Rulings Issues Papers:

• Bodies corporate - GST registration
• Unit trusts - whether more than 1 unit holder is required

IRD Questions We’ve been asked:

• Abusive tax position
• ASC of an amalgamated company
• Tax avoidance and debt capitalisation
• Companion's travel expenses
• Depreciation roll-over relief
• Entry of a new partner - draft QWBA
• GST - Whether a binding contract always establishes a transaction giving rise to a supply
• GST on compulsory acquisition of land
• GST on hire firm security bonds
• GST on late return charges (including library fines and parking fines
• GST on lotteries, raffles, sweepstakes and prize competitions
• GST on transfer of an interest in a partnership - draft QWBA
• GST on transfer of an interest in a partnership
• Insurance: sickness and accident insurance taken by employee and employer pays premiums - draft QWBA
• Insurance: sickness and accident insurance taken by employer for employee - draft QWBA
• Insurance: term life insurance taken by employee and employer pays premiums - QB 15/05
• Insurance: term life insurance taken by employer for employee - QB 15/06
• LTCs interest deductibility QWBAs
• Non-profit bodies - Registration, accounting for GST - draft QWBA
• Residual land
• Whether land part of an undertaking or scheme can be disposed of without income arising
• Revenue account land - whether cost of option is part of cost - draft QWBA
• Retention money
• What is significant expenditure in a major development or division - QWBA
• Tax avoidance scenarios (draft QWBA - early version)
• Tax avoidance scenarios (June 2015 draft QWBA)
• QB 07/03 Trustees of multiple trusts
• UK pensions and foreign tax credits

IRD Standard Practice Statements:

• Exposure draft on SPS Requests to amend assessments

IRD Statements:

• GST - Matrimonial property agreements

Land:

• Bright-line test IP
• Land acquisition date IP
• Land related lease payments IP
• Land transactions information gathering and enforcing offshore persons’ tax obligations in Taxation (Land Information and Offshore Persons Information) Bill
• Residual land QWBA
• Whether land part of an undertaking or scheme can be disposed of without income arising - QWBA
• What is significant expenditure in a major development or division - QWBA
• What is significant expenditure in a major development or division - Commissioner's operational position

Lease payments:

• Land related lease payments IP
• Lease inducements amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• Leases on land amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Lease inducements and lease surrenders amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Lease inducements 2014 enacted amendments
• Leases on land 2014 enacted amendments
• Lease surrender payments enacted 2014 amendments
• PDF attachment on lease payments

LLCs:

• LLCs
• LLCs Part 2

Mixed-use assets:

• Mixed-use assets (rules as introduced - significant changes since then)
• Mixed use assets exemption repealed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Mixed-use assets GST

Non-profit bodies:

• Non-profit bodies - Registration, accounting for GST - draft QWBA

Non-residents:

• Non-residents GST registration (rules as introduced)
• Non-residents GST registration (rules as enacted)

Non-resident withholding tax:

• NRWT: proposed changes affecting related party and branch lending IP (defining income for NRWT)
• NRWT: proposed changes affecting related party and branch lending (restricting AIL and branch exemptions)

Non-tax bills:

• Companies and Limited Partnerships Amendment Bill
• Financial Markets Conduct Bill
• Financial Reporting Bill

Partnerships:

• Entry of a new partner - draft QWBA
• GST on transfer of an interest in a partnership - draft QWBA

Reporting requirements:

• Special purpose reporting requirements amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced

Research & development:

• Black hole R&D expenditure DD
• Budget initiatives 2014 - black hole R&D
• Budget initiatives 2014 - cashing out R&D tax losses
• R&D tax losses IP: current rules
• R&D tax losses IP: proposed new rules

Residence:

• Residence draft IS: natural persons
• Residence draft IS: companies and trusts
• Residence IS 14/01: natural persons
• Residence IS 14/01: companies
• Residence: Commissioner's transitional operational position
• Residence TRA 43/11 [2013] NZTRA 10

Retirement villages:

• Retirement villages - GST treatment - draft IS

Salary Trade-offs:

• Salary trade-offs as income Issues Paper
• Short term charge facilities amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill

Share ownership:

• Share transfers timing IS

Shareholder decision-making rights:

• Whether rights under Companies Act 1993 give rise to a shareholder decision-making right IS

Subdivision of shares:

• Subdivision of shares BR Pub

Tax Bills:

• Bad debt deductions amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Bad debts deductions amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Black hole amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Black hole resource consents amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Earthquake relief additional amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill SOP
• Financial reporting requirements amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation amnesty extension in SOP to Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals tax inclusions and exclusions amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax assessable period and formula method amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax schedule method and KiwiSaver withdrawals amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Foreign superannuation withdrawals tax inclusions and exclusions amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals assessable period amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• FIF superannuation interests amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals KiwiSaver withdrawals amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Foreign superannuation withdrawals Schedule method and formula method amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• 15% temporary amnesty in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• 15% temporary amnesty extension in SOP to Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• GST amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• GST Apportionment rules and zero-rating of land rules amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• GST remedial issues amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Imputation credits on Australian dividends amendments proposed in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as reported from the Select Committee
• Imputation credits on FIF income amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• International Investment Tax Bill
• Land transactions information gathering and enforcing offshore persons’ tax obligations in Taxation (Land Information and Offshore Persons Information) Bill
• Lease inducements amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• Leases on land amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Lease inducements and lease surrenders amendments proposed in Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill
• Tax treatment of notional interest under IFRS amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• Short term agreements as financial arrangements amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• Short term charge facilities amendments in Taxation (Livestock Valuation, Assets Expenditure, and Remedial Matters) Bill
• Special purpose reporting requirements amendments in Taxation (Annual Rates, Foreign Superannuation, and Remedial Matters) Bill as first introduced
• GST on body corporates amendments in Taxation (Annual Rates for 2015-16, Research and Development, and Remedial Matters) Bill as first introduced

Tax cases:

• Alesco Court of Appeal case
• BNZ avoidance case
• Concepts 124 Ltd - companies associated through control by a corporate trustee for GST purposes
Concepts 124 Limited v Commissioner of Inland Revenue [2014] NZHC 2140
• Re Greenpeace of New Zealand [2012]- Court of Appeal case
• Re Greenpeace of New Zealand Incorporated [2014] - Supreme Court
• GST cases – Qantas
• GST cases – Thompson
• GST cases – ID Tours - GST on advisory tourism services
• Sovereign Assurance Court of Appeal decision - Interpretation of financial arrangements rules
• TRA 021/12 [2013] NZTRA 11 - GST groups other than companies
• TRA 43/11 [2013] NZTRA 10 individual tax residence
• TRA 001/13 [2014] dividend stripping case
• TRA 023/12 [2014] NZTRA 10: Whether agreement became binding before or after GST rate increase
• TRA 008/14 [2014] NZTRA 15: Input tax restrictions on supplies between associated persons
• TRA 008/13 [2014] NZTRA 17 whether expenditure on land part of a business
• TRA 02/10 [2015] NZTRA 01 when 2 companies are associated for GST
• TRA 013/10 [2015] NZTRA 10 management fees paid by a trust
• Trustpower Ltd v CIR - tax deductibility of resource consent costs (HC)
• CIR v Trustpower Ltd - tax deductibility of resource consent costs (CA)
• Westpac avoidance case
• GST cases – Wyatt v Real estate Agents' Authority

Thin capitalisation:

• Thin capitalisation – Interest-income ratio
• Thin capitalisation IP
• Thin capitalisation - non-resident shareholders acting together
• Thin capitalisation - non-resident shareholders acting together - NZ Group
• Thin capitalisation - non-resident shareholders acting together - Worldwide Group
• Thin capitalisation technical issues
• Thin capitalisation - extended application to trusts
• Thin capitalisation - PDF attachment on 2014 amendments

Transaction structuring:

• Transaction structuring

Trusts:

• Trust beneficiary income in Australia
• Trust beneficiary income NZ
• Trust beneficiary income vs tax beneficiary income IS
• Whether a beneficiary will be treated as a settlor where there is no loan - draft ruling
• Whether a beneficiary will be treated as a settlor where there is a loan - draft ruling

Unclaimed money:

• Unclaimed amounts of $100 or less BR Pub

Unit trusts:

• Unit trusts - whether more than 1 unit holder is required

US Investments:

• LLCs
• LLCs Part 2