Other tax matters on which we provide expert and practical advice include (in alphabetical order):

  1. Asset protection: company/trust structures and use of a corporate trustee
  2. Attribution of income rules and  application: including possible need to pay market salary to personal services provider (following TRA case V20/W33, Penny & Hooper cases, IRD audit activity)
  3. Business ventures: advice on start up, restructuring and sale and purchase of business ventures including companies, trusts and trading trusts – issuing, buyback or cancellation of shares, capital gains, dividends, waiver of dividends, adding or removing members of a partnership, assignment of interests to family trusts, NZ and various international investors
  4. Debt reconstruction: for example eliminating overdrawn shareholder-employee current accounts, intercompany debt
  5. Deduction of expenses: capital vs revenue
  6. FIF and PIE regimes: calculation of income/loss
  7. Imputation credits: access by shareholders, continuity, overdrawn imputation accounts, further income tax, IRD cancellation of old credits, penalties and successful reversal
  8. Liquidations: tax issues arising on voluntary windup/liquidation, GST on mediated settlement and related legal expenses, legal expenses incurred in defending claims from liquidator.
  9. Qualifying companies and look through companies
  10. Shareholder continuity; for loss and inputation purposes
  11. Time-bar: for income tax, GST, losses
  12. Use of money interest (UOMI)