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With limited exceptions the trustee tax rate has increased to 39% effective 1 April 2024. Note that for deceased estates: For disabled beneficiary trusts: For more information see Trust and estate changes. References: Tax Bill receives assent (ird.govt.nz)
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 rules that tax certain sales of land include exclusions relating to a person’s main home. These exclusions are not meant to apply where the taxpayer has a “regular pattern” of buying and selling land used as a main home, residence or business premises. A tax policy consultation document, Habitual buying and selling of land, released … Continue reading
The judgment in Full-Circle Staffing, LLC, Watchman Investment Trust, Financial & Tax Services, Inc., Trustee, Tax Matters Partner, Et Al. v Commissioner of Internal Revenue (Full Circle) is a consolidated judgment of the United States Tax Court. The background facts are complicated but can be summarised as follows: Mr and Mrs Pudlo restructured their freight forwarding … Continue reading
The taxation of trusts is a dynamic and ever-changing landscape. The third edition of Taxation of Trusts published this week (September 2016) has been up-dated to incorporate recent case law developments and legislative amendments. The text also considers the application of FATCA to trusts and proposed new reforms to the disclosure rules and closely … Continue reading
Inland Revenue has issued a QWBA (QB 15/11) regarding whether a trustee exercising a discretion to distribute trustee income (that would be taxed at the trustee rate of 33% if retained by the trustee) to a beneficiary on a lower tax rate, a beneficiary with tax losses or a beneficiary to whom the income will … Continue reading
Trusts are the best long-term intergenerational form of asset protection. However, as litigation involving trusts increases, questions are reasonably asked regarding the “safety” of trusts. If you are looing for answers or guidance Vicki Ammundsen is presenting a webinar on February 19th discussing the fundamentals of trusts. Topics covered by the webinar include: Requirements of a valid trust Differentiation between … Continue reading
The Court of Appeal has upheld the High Court decision in Glover No 2 Limited v Glover Trust Limitd et ors that a deed of bare trust that was entered into only to avoid a tax liability was a valid document and did not represent a sham. The deed of bare trust was entered into to … Continue reading
On 31 August 2011, Inland Revenue issued Revenue Alert RA 11/02. This Revenue Alert sets out the Commissioner’s views in response to the decision in Penny and Hooper as to when diverting personal services income through an associated entity such as a trust will constitute tax avoidance. Key provisions The main points of the Revenue Alert can be … Continue reading
Matters of Trust 