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Inland Revenue has issued a General Article (GA 24/01) providing guidance regarding how Inland Revenue might perceive certain transactions and structure changes. In GA 24/01 Inland Revenue provides high level guidance regarding specific transactions and structural changes that are unlikely to be considered tax avoidance (without artificial or contrived features) such as distributions of income … Continue reading
The bright-line test will return to a 2 year period effective from 1 July 2024. Finance Minister Nicola Willis has advised as part of the new coalition Government’s mini-budget: “Today I am announcing our immediate decision to bring the brightline test for residential property back to two years, effective from 1 July 2024. Removing this … Continue reading
Blind Foundation bulldozes $8m Parnell house, creates carpark is an emotive headline from the New Zealand Herald published on 27 July 2019 that highlights the disconnect between registration as a charity and the tax benefits that flow from this, and highlights the reality that registration as a charity does not obligate a charity to distribute its … Continue reading
The bright-line test came into force on 1 October 2015. When the legislation was at Bill stage it was signalled that the bright-line test was intended to come into force on 1 October 2015, as was the case. GG & GE Blackburn Trustee Limited (the Trustee) is the trustee of the Blackburn Family Trust (the Trust). On … Continue reading
The High Court decisions, Concepts 124 Ltd v Commissioner of Inland Revenue [2014] NZHC 2140 and Staithes Drive Development Ltd v Commissioner of Inland Revenue [2015] NZHC 2593 have resulted in uncertainty surrounding the application of the voting interest test for corporate trustees . See Corporate Trustee Associated for GST purposes In both cases, the … Continue reading
Matters of Trust 