2021 onwards

Description Owens Tax achievement
Advised on changes in tax residence and application of transitional residence to UK migrants, including the implications for UK ISAs and other superannuation and pension investments. We established tax residence position, resulting NZ tax obligations, and specific advice on the repatriation/transfer of funds to New Zealand.
Developed a summary of key land taxing provisions for use by general business consultants. This summary enabled the business advisors to provide general guidance on land transactions and a clear decision tree as to when specific professional tax advice would be required.
Advised a UK national on tax residence retiree on tax residence changes and other implications following a delayed relocation to New Zealand during COVID. We established NZ tax residence status and application of transitional residence rules to exclude most worldwide income from NZ tax.
Review employment related loans and the private use of motor vehicles to determine the resulting Fringe Benefit Tax payable.   Minimised the FBT exposure through applying legislative concessions, facilitated an unsolicited voluntary disclosure and provided specific commercial action points to reduce FBT exposure even further going forward.
Determined tax implications of a subdivision proposal involving land parcels with different acquisition dates and with differing development activities undertaken. We successfully excluded capital gains made from some land parcels from income tax.
A Canadian couple migrated to NZ but retained real property and other investments in Canada. We advised on the application of residence and transitional residence rules and application to their various investments and income sources
GST claimed on a lifestyle property was not fully considered at the time of a marriage dissolution and divorce, or subsequently upon the transfer of the property to a family trust, or cessation of the small agricultural activity.    We determined the implications and proactively resolve the matter with IRD by way of a voluntary disclosure with minimum outlay for our client.
A NZ expat returned to NZ after twenty years abroad but continued to work for his European employers, whilst being based in NZ.  IRD questioned the source and tax treatment of recent receipts We determined his tax obligations, determined his income tax shortfall and facilitated a voluntary disclosure with IRD – limiting the tax impost, eliminating penalties and mitigating interest.
Determined the NZ tax implications arising in respect of income earned by a UN employee working remotely in New Zealand during COVID lockdowns. Determined implications of current arrangements and recommended an appropriate practical structure including implementation steps.
Considered tax implications of proposed land transaction sale for two brothers with extensive land interests.   Successfully concluded sales were not subject to income tax.
Liaised with IRD on behalf in relation to an audit notification in relation to purported application of the Brightline Provisions to real property. Submitted a voluntary disclosure of a number of outstanding matters and previous errors of clients with practical solutions in each case, minimising  tax and GST exposure and secured IRD acceptance of same.
Determined tax residence position and any resulting New Zealand income tax obligations in respect of a NZ expat who has now spent in excess of ten years as crew member on large yachts. Provided clear responses to each of the client’s 11 specific questions regarding their tax affairs – including application of transitional residence rules, repatriation of house sale proceeds, consequences of purchasing land in NZ, etc.
Provided advice to a NZ expat now based in Australia on the New Zealand tax implications for his various investments and income. Concluded tax residence status through application of NZ and Australian and overriding double tax agreement residence tests.  Provided a specific action list of what income should be included in NZ vs overseas income tax returns for specific periods.
Reviewed proposed partnership allocation of income  Provided clear guidance and advised on practical measures to increase robustness of the tax positions to be taken in future years.
A non-resident owned a residential rental property in New Zealand.  The property was initially owned by a married couple, and then recently changed to one partner and their adult child.   Later still the property was sold to a third party. Analysing the Brightline Provisions we utilised further tests to detemine the property was not subject to income tax under the Brightline Provisions or to Residential Land Withholding Tax on sale.  [note this job is not yet finalised]
Assisted a Canadian expat following migration to NZ with deterring her NZ and Canadian tax liabilities and liaising with her Canadian accountant to have tax returns reassess to avoid excess Canadian income tax. Eliminated double taxation and assisted with arguments to seek cash refunds from the Canadian Revenue Authority for excess income tax paid in Canada. 
A NZ expat relocated back to New Zealand and continuing to derive Australian income. Provided advice and ongoing assistance, ensuring consistent treatment between the two jurisdictions
Analysed the sale of separate land interests held by two close relatives as tenants in common and(following a dispute)  part occupation by one of them and the resulting implications for the Brightline Provisions. Confirmed tax exempt status following application of Brightline exemptions.
Advised Canadian migrants on the application of residence and transitional residence rules and application to retained real property and other investments in Canada. Our advice enabled the clients to consider both the commercial and tax impact of the timing of their proposed relocation to New Zealand and a potential sale of Canadian property.
Provided advice on the application of Brightline Provisions to a young couple’s sale of a residential section that had been acquired to build a personal residence on, minor development was undertaken, and was then sold.   We successfully concluded that the sale was not taxable under the Brightline Provisions.
A company was going through restructuring and one shareholder was wanting to transfer her shares to another shareholder.  The company had substantial imputation credits. We undertook detailed analysis of share transactions and established that the proposed shareholding transfer did not cause a breach of shareholder continuity for imputation credit purposes, and as such, the imputation credits of the company were retained.
Assisted with IRD review of GST implications following a property sale. We agreed a position with IRD to determine a GST output tax liability mitigating core tax, and interest and penalty exposure.
Advised on the NZ tax implications of the provision of services in Belgium and application for the double tax agreement to income earned. We identified an alternative structure to that originally proposed by the client that did not attract double taxation and was commercially more attractive.
Advised a NZ expat who had spent in excess of two decades residing in London on the NZ implications of a potential relocation and how her investments would be taxed, and application of the Transitional Residence provisions. Advised tax free nature of UK pension and superannuation investments and provided  clear guidance on the tax implications for various forms of worldwide income derived during different time periods.
Provided detailed advice and recommendations on GST and income tax obligations arising from the personal use of a mixed use property held in a company name. This enabled the client to be fully aware of their obligations and ensure tax liabilities were mitigated.
Advised a NZ expat with income sourced from Thailand and Singapore on the NZ tax obligations in respect of those investments  We were established that no NZ tax liability arose.
Determined the New Zealand tax implications arising for a NZ expat executive in relation to employee share scheme participation and receipt of bonus payments from an Australian company, pertaining to employment exercised in Thailand, and received after relocating and resuming NZ tax residence. We determined that bonuses and other remuneration received while resident but pertaining to periods prior to residence were excluded from income taxable in NZ.
Considered the international tax implications for a NZ national who had an extended OE in Australia and Canada and established significant personal connections and ties in all countries.  Our analysis and determination of the client’s tax residence position enabled us to provide a specific conclusion as to what income was taxable during specific periods of time during which she was resident, non-resident, a transitional resident and thereafter.  
Advised on the potential Brightline Provisions implications for land transferred between two trusts with identical trustees. Provided certainty on the application of the Brightline Test.
Provided specific land transaction advice in relation to a sale of substantial property asset in NZ by a UK couple as part of a relationship property matter. We were established that despite substantial development and never occupying the property as a primary residence, there were no taxable implications arising.
Completed an unsolicited voluntary disclosure of historic investment in a UK pension scheme that had not previously been returned for NZ tax purposes, limiting amended returns to recent years only, and avoiding the imposition of any shortfall penalties. We were successfully limited exposure to recent tax periods.  As a result, the client’s exposure was capped, penalties were avoided, and interest costs minimised.
Determined the tax residence position of a yacht captain relocating to New Zealand. We established NZ tax residence status and application of transitional residence rules to exclude most worldwide income from investments from NZ tax.
IRD queried a builder who was disposing of a dwelling that had been used as both a show home and base for business activities, and queried a number of other matters. We determined tax and GST implications, and drafted a Voluntary Disclosure that was ultimately accepted by IRD – resulting in payment of GST on one matter only and without any cash income tax adjustments.
A NZ expat relocating to NZ after spending 20 years in the UK also had connections to Thailand where his wife lives. Owens Tax detemined the residence implications, transitional residence implications and application of the UK and Thailand double tax agreements.  Through careful analysis we provided certainty to this client around the dates of change of residence etc and the corresponding impact on his various global tax obligations.
Liaising with IRD in respect of undeclared overseas bank accounts and business income arising. After analysing the related party and cross border transactions within a family group of entities, we determined and agreed materially lower adjustments and additional income tax payable than was first sought.
Provided advice on international tax residence implications for an historically nomadic client who was forced to reside in New Zealand longer than normal due to COVID lockdown and travel restrictions. We determined NZ tax residence status and application of transitional residence rules to exclude most worldwide income from NZ tax.
A US and NZ dual citizen and his US citizen spouse raised tax queries in respect of the NZ implications of their US assets and income.   We provided definitive advice on the NZ tax implications and application of the NZ-USA Double Tax Agreement.
Advised a UK resident on the tax implications of earning rental income from relatives in relation to a NZ property.  Established the ownership for tax purposes despite different legal and equitable owners.
Advised a UK tax resident on the NZ tax implications arising in respect of a proposed purchase of an interest in NZ property. Using our advice on the different implications of commercial vs residential ownership, the client was able to consider the appropriateness of different investment opportunities and make an informed commercial decision.   
A New Zealand citizen spent his entire career in the UK, then retired and established some connections with New Zealand including a holiday home and spending several months in New Zealand each year.  In addition, during 2020 and facing the restrictions imposed on global travel from COVID-19, this client spent considerably more time in New Zealand than he had previously.   After considering the relevant background, legislation and case law, and IRD concessions relating to the impact of COVID-19 on tax residence positions, we provided specific advice on the tax implications of his residence position and favourable tax implications of lump sum superannuation withdrawals from his UK superannuation fund.
A commercial property owner developed a commercial property into a modern hotel and proposed to sell the business as a going concern to a third party before commencement of operations.  The transfer included substantial intangible property, some fixed assets, along with a requirement to lease the property from the owner. We advised appropriate contract wording to ensure GST exposure did not arise, and confirm which elements of any proposed sale would be income, able to be spread over a number of years, and exempt from income.
A retired couple wished to deregister for GST whilst retaining a mixed use property asset. We provided advice in relation to the GST implications of GST deregistration including identifying a practical solution utilising differing valuation criteria for differing portions of the property and successfully challenging a position proposed by IRD
Advised a NZ expat who had been based in Australia for a number of years on tax residence changes and availability of transitional residence regime upon return to New Zealand given continued ownership of NZ property and connections during her absence. Supported the client to revisit previously lodged Australian income tax returns that had incorrectly included NZ income, and provided the basis for future NZ income tax returns.
Advised of the tax, PAYE and FBT implications arising from agreed transactions occurring as part of the resolution of a commercial dispute. Assisted with mediation between parties by providing confirmation of FBT implications on various transactions. 
Provided international tax advice in respect of a NZ farmer with connections and investments in Sweden and potential tax residence changes, following expected duration of presence in both countries. As a result, the client was able to make informed decisions about potential relocation and investments. 
Advised on the income tax and GST implications of a potential transfer of land to be used within a homestay business. We established the potential impact of the Brightline Test, changes to interest deductibility, and commercial merits of a discretionary trust to hold a dwelling used for homestay; in turn providing clear recommendations as to the most appropriate path forward.
Trust derived rental income from a beneficiary but had not previously returned the income. Calculated the net taxable income arising from the rental activity and successfully submitted a voluntary disclosure to IRD to return that income without penalty or further cost imposition.
A NZ expat academic returned to NZ after spending many years abroad in Australia but continued to earn Australian sourced income. We determined tax residence, Transitional Residence exemption on foreign income, and overriding application of the Australia and NZ double tax agreement.  This enabled the client to meet her compliance obligations in respect of her employment, rental and investment income with clarity. 
A NZ resident that spent some time in Australia purchased residential property while living there in the early to mid-nineties.  These units were sold in 2022 and her accountant became aware of them for the first time.  Rental income and any capital gains had never been returned in Australia or New Zealand. We determined the NZ and likely Australian tax implications, and provide a clear action plan to the client to remedy the shortfalls in both the Australian and NZ tax positions.
A NZ tax resident was offered a secondment role in Australia for a fixed term, including various allowances, accommodation, and other benefits. We provided advice on his residence implications and the various tax implications arising for each component of his proposed remuneration package; thereby enabling him to make an informed decision whether or not to accept the offered role.
A deceased estate held titles with multiple dwellings on them and, in order to realise the greatest return for the beneficiaries, the executors subdivided the properties prior to sale of individual lots/dwellings to third parties. Provided certainty on the GST and income tax implications of the executors carrying on a subdivision activity.  We secured IRD agreement to claim GST in respect of building costs incurred by the deceased many years prior.
Two Australian citizens that had spent some 20 years living and working in NZ, then returned to Australia for a further 20 years, before ultimately returning to live in NZ. We determined the tax residence conclusions for each individual, availability of the Transitional Residence exemptions on foreign income, and overriding application of the Australia and NZ double tax agreement.  This enabled the clients to meet their compliance obligations in respect of their employment, rental and investment income with clarity. 
an Indian national migrated to NZ but continued to derive Indian sourced rental, interest and other investment income. Provided advice on the NZ tax implications arising and submitted a voluntary disclosure.
Advised on the GST implications of the purchase and subsequent demolition of a large apartment block with a view to erecting a new block of apartments Confirmed the application of GST zero rating provisions and the availability of a second hand goods input tax credit.
Provided detailed advice in respect of a New Zealand expat now earning employment income from Saudi Arabia whilst physically present for sustained periods in the Middle East.  We determined the impact on tax residence and the resulting worldwide tax implications of this arrangement, including forced additional presence in a single location during COVID lockdowns and travel restrictions, in fact excluding NZ tax residence
Confirmed associated person land provisions application and non application to sales of improved and unimproved land by entities connected to a builder. Capital gains made on the sale of some properties were not tainted and not subject to income tax.
Provided advice on the NZ tax obligations arising from the sale of a German property by a NZ resident taxpayer.  We provided a practical suggested action plan, eliminating NZ tax liabilities.
Advised on the application of the land transaction provisions to a potential sale of farmland comprising different parcels with different acquisition dates and upon which some development had taken place. We were advised the client of the potential income tax implications and secure tax free status for the capital gain derived prior to development commencing.
Analysed the application of Brightline Provisions applying to a property comprising separate land interests with different acquisition dates and one interest being acquired from an associated person. Sales of the relevant properties were able to be effected with clear understanding of the taxation implications applying. 
Advised a South African national on New Zealand tax implications of various investments retained in South Africa following his relocation to New Zealand – including foreign pension, foreign investment fund and financial arrangement provisions. Following our analysis and confirmation of the taxation implications under both NZ legislation and the South Africa and New Zealand double tax agreement, we identified a material foreign tax credit available to offset this client’s NZ income tax liability.
Advised a crypto currency operator of the New Zealand tax obligations of operating in New Zealand including implications for the NZ operating entity, and holders of the currency itself. Advised on the GST and income tax implications of accruing, holding and selling crypto currency, and receiving crypto currency as a reward for service.
Reviewed technical positions in respect of issues identified by IRD during an audit and successfully negotiated positive GST and income tax positions arising from the sale of the property. We identified a practical outcome whereby GST and income tax payable were based on older historic valuations and saved tens of thousands of dollars.
Advised a NZ expat based in Asia on the tax implications of various New Zealand investments in property, forestry and carbon related ventures.  Outlined a clear taxation framework for the investor to understand the potential implications of his various commercial investment decisions.
A husband and wife that had relocated from NZ to Australia some years ago continued to hold previously subdivided property in NZ through a family trust.  They recently returned to New Zealand to avoid COVID-19 concerns and, while here, inherited further property.   We advised on the application of NZ land tax provisions, residence rules and the application of the Australia-NZ Double Tax Agreement to determine the non-taxable nature of any land sales for this couple.
Completed a voluntary disclosure in respect of GST erroneously claimed on a GST zero rated acquisition of land. We successfully limited GST adjustments to being based on historic values.  As a result, the client’s exposure was capped, penalties were avoided, and interest costs minimised.
Provided advice and practical recommendations to an Irish national who migrated to NZ and spent considerable time in the USA earning income there. We advised on residence position and application of double tax agreements to ensure there was no double taxation of income.
Advised on GST implications arising in relation to the use of a residential portion of property within an Airbnb operation. We identified an alternative option that the taxpayer could use to calculate the GST adjustments required resulting in an ability to deregister for GST and saving tens of thousands in GST otherwise payable.
Advice in respect of NZ tax residence and implications including transitional residence and implications for foreign sourced income. We excluded from taxable income some significant bonuses and other remuneration received while resident but pertaining to periods prior to residence.
Assisted a returned NZ expat who had spent time in Australia and liaise with her Australian accountant to secure correct and minimised tax in Australia on her income. This client’s Australian advisors had incorrectly determined her Australian income tax liability and we refered them to the appropriate savings provisions with the Australia and New Zealand Double Tax Agreement, and in doing so saving thousands of dollars in taxation.
Provided advice on the NZ tax obligations arising from the sale of a German property by a NZ resident taxpayer. We provided a practical suggested action plan, eliminating NZ tax liabilities.
Assisted an accountant in responding to IRD queries in relation to a client’s payment of an unapproved salary to a spouse. Negotiated an agreed practical outcome with IRD to amend structure going forward with no changes to historic position.
Determined the New Zealand tax implications arising for a NZ expat executive in relation to employee share scheme participation and receipt of bonus payments from an Australian company, pertaining to employment exercised in Thailand, and received after relocating and resuming NZ tax residence. Confirmed excluded some income and calculated reduced taxable income.  
Considered the potential application of Brightline Provisions to an interest in real property acquired through transmission under a bare trust. We provided guidance on the implications of the proposed transfer and determined there would be no income tax obligations in respect of a transfer under a bare or constructive trust.
Confirmed the New Zealand tax implications of UK pension withdrawals for a New Zealand immigrant who had acquired interests in those pension funds prior to migrating to New Zealand many years ago.  Advised the tax implications arising for transfer/withdrawal of a UK pension fund.
Provided detailed structuring advice in respect of a proposed acquisition and subdivision of land for both resale and in order to acquire a residence for the clients. Successfully separated a portion of land acquired for the purpose of personal residence from land acquired for the purpose of development and resale; thereby ensuring that portion remained free of income tax obligations.
Prepared and submitted a voluntary disclosure to IRD following a request for information in relation to a large investment portfolio held in the Uk that been bequeathed to a NZ resident upon the death of a relative.   We successfully limited exposure to a four-year period.  As a result, the client’s exposure was capped, penalties were avoided, and interest costs minimised.
Assisted a client with unintended GST consequences arising from claiming GST in respect of home office expenses and subsequent cessation of the taxable activity. We determined a GST output tax liability with IRD using historic values rather than current values.
Advised on changes in tax residence and application of transitional residence to UK migrants, including the implications for UK ISAs and other superannuation and pension investments. Set out preliminary advice on likely tax residence status in New Zealand, and implications for residential properties, pensions and foreign
A builder had various different entities connected with his building business, each with their own land transactions. We advised on the potential application of associated persons tests within the land transaction provisions. 
A client was concerned about potential claims on his estate (in the future) by an estranged son and wanted to protect his wife and daughter from such claims. We identified an appropriate structure and related steps to implement with no direct tax implications and achievement of his commercial objectives.
Determined the New Zealand tax implications arising for a NZ expat executive in relation to employee share scheme participation and receipt of bonus payments from an Australian company, pertaining to employment exercised in Thailand, and received after relocating and resuming NZ tax residence. Successfully excluded remuneration earned before commencing NZ residence from NZ income tax despite being received subsequently; calculated the NZ tax implications arising from participation in an employee share scheme.
Advised trustees of the tax implications including potential application of Brightline Provisions.  We recommended a practical course of action mitigating any income tax liability.
Provided advice on the potential land transaction provisions application to the sale of land from a company to a related trust. Being cognizant of the specific risk of tainting the relevant property for income tax purposes, the client was able to make an informed decision about alternative proposals.
Responded to IRD on behalf of Chinese migrants to New Zealand who were subject to IRD review following foreign data matching activity of IRD.   A comprehensive voluntary disclosure was submitted and agreed with IRD, mitigating penalties and interest costs, together with minimal underlying income tax.  This project including translation of Chinese language investment and bank statements
Analysed a taxpayer’s various share and investments transactions and provided advice in respect of the potential taxation in NZ under revenue account property provisions. This provided assurance to the client that his tax return obligations were satisfied and tax liabilities mitigated.
A NZ tax resident who had spent some time in the UK in the nineties maintained membership in a UK pension fund, subsequently transferring the balance in 2018 to QROPS scheme fund in NZ.  We determined what portion of any transferred amount was subject to taxation, calculated the amount of income under various available methodologies and facilitated an unsolicited voluntary disclosure using a method giving rise to substantial tax savings.
Assisted a client immigrating from Ireland with tax residence, transitional residence and application of Brightline Provisions to a property sale. We provided advice on this client’s past and future NZ tax obligations enabling her to make an informed decision about appropriate steps to take.
Determined tax implications of a subdivision proposal involving land parcels with different acquisition dates and with differing development activities undertaken. Applying tax legislation and established land taxing principles from case law we assessed the land related activities of the landowner, associated personas and transactions affecting the land in question to determine and provide assurance as to the taxation implications of a proposed sale.
Advised of the New Zealand financial arrangement implications arising for a NZ resident with complex Netherland banking arrangements. We provided detailed advice on the application of the financial arrangement regime and suggest a practical solution to address past income years.
Advised the GST implications of the sale of mixed use land that had been used for both residential and commercial purposes. Provided clear advice on the GST implications and exposure risks concerning going concern and continued GST registration, thereby providing clear guidance for associated decision making. 
Calculated Financial Arrangement and Foreign Investment Fund income arising from a number of foreign investments previously undisclosed to IRD, and now subject to and IRD review. Although the taxpayer had initially incorrectly excluded this income, we identified other favourable adjustments such that further income tax was not payable in respect of recent income years.
Advised trustees of a family trust of the income tax consequences arising from the disposition of real property to another upon a resettlement of one trust on to another. Provide advice on the income tax implications under Brightline Provisions for transfer of a property between two related trusts upon resettlement, and recommended deferral of certain transactions
Assisted a mutual association to correctly determine income and expenditure based on legislation and IRD’s acceptance of the mutuality principle. Successfully interacted with IRD to secure acceptance of our proposed position and a positive binding ruling on the same.
An expat NZ citizen was looking to return to NZ after working and living abroad in China, Germany and then Israel for a number of years. We determined his non-resident status, the implications for different employment and contracting and investment income, and the application of some double tax agreements, and implications where there were no such applicable agreements including possibly recovery of excess tax paid in Israel.
Considered the subdivision of four sections from a larger parcel of land and the potential application of the land taxing provisions.   We established that the sales of properties were not ‘caught’ under ‘subdivision-within-ten-years’, ‘significant expenditure’ or ‘profit making undertaking or scheme’ provisions.
A NZ resident couple with mirror trusts holding significant investments wanted to repatriate funds held in an Australian Superannuation Fund to the trusts in NZ.  . Applying NZ’s Foreign Investment Fund and Foreign Superannuation rules we provided a practical action plan to transfer the funds to New Zealand without any tax impost in Australia or New Zealand
Reviewed a potential purchase of a mixed use property.   We provided advice and ultimately recommendations following consideration of the cashflow impacts of GST arising from different acquisition structuring and the proposed property use.
A UK citizen and her partner with a majority interest in a UK company began spending some time in NZ while holding a work to residence visa; before then relocating to NZ permanently some years later.   We determined application and timing of New Zealand’s transitional resident regime to exclude foreign income, including dividends from the UK company for a four year period.
Advice in respect of residence for tax purposes, transitional residence and NZ tax treatment of transfer of UK investment to NZ. Established the tax implications arising for transfer/withdrawal of a UK pension fund.
Revied specific forestry and trust provisions to assist an accountant determining his client’s beneficiary income arising from retrospective spreading of forestry income. Successfully convinced IRD to accept retrospective allocation of forestry income derived via a discretionary trust to prior income tax years.
Considered the application of various land taxing provisions to a number of various jointly held interests in land. Provided a clear recommendation of gains to be included and gains that could be excluded from taxable income and outlined an action plan for addressing those with IRD.
Advice to non NZ tax resident We provided comment on the client’s tax residence position, the application of the UK and NZ double tax agreement and the resulting implications for various forms of income he received.
A young client purchased his first home from a related family trust, occupied it initially before renting it to third parties and moving in with his partner. We detemined the Brightline Acquisition date, and, prior to entering into any agreement for sale, provide confirmation of the application of a main residence exemption.
Assisted a taxpayer with a voluntary disclosure in relation to GST and income shortfalls in respect of a mixed use commercial property. We successfully capped, the client’s exposure, penalties were avoided, and interest costs minimised.
Reviewed application of NZ Controlled Foreign Company rules, tax residence rules, an applicable double tax agreement, income attribution rules and GST implications in respect of a Switzerland company used to provide global consulting services from a NZ based principal.   Determined implications of current arrangements and recommended an appropriate practical structure including implementation steps. 
Analysed the potential implications on taxation of trust income and beneficiary distributions following changes to trustees and beneficiaries. Identified concerns and potential double taxation arising from the use of a discretionary trust with non-resident trustees and beneficiaries.  We determined there were no NZ implications and provided a suggested action plan to mitigate risk going forward.
Analysed the residence position and resulting New Zealand tax obligations of a Canadian couple migrating to New Zealand, including the implications arising in respect of Canadian pensions, rental property held in Canada and interest income.   Applied the double tax agreement to ensure the best possible position was able to be adopted.
Advice in respect of tax residence for a Singaporean national with business investments and real property in NZ. We provided advice in respect of tax residence, company investments and provide assurance as to the implications of change in ultimate shareholding of a NZ company.
Reviewed land transactions to determine application of Brightline Provisions and other land taxing provisions to land that was transferred from joint tenancy to tenants in common.   We determined that transaction and subsequent subdivision activity did not give rise to any taxable income.
Considered the international tax implications arising from a proposed distribution of a large capital gain from a NZ based family trust to an expat NZ national temporarily tax resident in Canada. Identified concerns and potential double taxation arising from the use of a discretionary trust with non-resident trustees and beneficiaries.  We established there were no NZ implications and provide suggested enquiry points for confirmation by a Canadian advisor.
Provided advice on tax residence and associated New Zealand tax implications for a Singaporean professional who migrated to New Zealand. Prepared the necessary calculations to determine New Zealand income from various financial arrangements and real property investments,  We were determined the professional’s NZ residence position and provide guidance on the application of both the Transitional Residence regime and the Singaporean and NZ double tax agreement, including detailed FIF calculations.
Assisted a client to determine the complying or other status of a family trust following relocation of trustees overseas. Identified concerns and potential double taxation arising from the use of a discretionary trust with non-resident trustees and beneficiaries.  We determined there were no NZ implications and provided a suggested action plan to mitigate risk going forward.
Provided our preliminary comments on likely taxation implications arising in NZ in relation to tax residence and USA social security Provided a comprehensive summary of current tax obligations in relation to foreign income including 401k.
Assisting with historic NZ tax obligations arising for an Italian National who became NZ tax resident and inherited substantial Financial Arrangement and Foreign Investment Fund investments following the passing of a relative. Despite a legacy obligation to return foreign income from investments held overseas and not repatriated to NZ, we were identified appropriate income calculation methods available to minimise taxable income, years re-assessed, avoid shortfall penalties, and mitigate IRD interest charges.  

 

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