Description: Class Q shares in ISAM Systematic Trend, to which this determination applies, are attributing interests in a foreign investment fund for New Zealand resident investors.

Description: Shares in the Russell Investments Multi Strategy Volatility Fund ('Russell MSV Fund'), to which this determination applies, are attributing interests in a foreign investment fund ('FIF') for New Zealand resident investors.

Description: Reimbursements or reimbursing allowances in relation to employee use of telecommunications tools and usage plans in their employment are taxable and subject to PAYE unless specifically exempt. Section CW 17 of the Income Tax Act 2007 allows reimbursements or reimbursing allowances to be exempt to the extent that an employee would be allowed a deduction if they incurred the expenditure and the employment limitation did not exist. Evidence is required to demonstrate a 'nexus' between incurring the expenditure and deriving income.

Description: A person has no attributed CFC income or loss from a CFC under sections CQ 2 and DN 2 of the Income Tax Act 2007 if the CFC is a non-attributing active CFC under section EX 21B of the Income Tax Act 2007 because the requirements of sections CQ 2(1)(h) and DN 2(1)(h) are not satisfied. Section EX 21B(3) of the Income Tax Act 2007 provides that a CFC is a non-attributing active CFC if it is an insurer that meets the requirements of section 91AAQ of the Tax Administration Act 1994 and the Commissioner makes a determination under that section. In the absence of such a determination, a CFC carrying on an insurance business is unlikely to be a nonattributing active CFC, because insurance income is otherwise treated as passive income and an attributable amount under section EX 20B(3) of the Income Tax Act 2007.

Description: A person has no attributed CFC income or loss from a CFC under sections CQ 2 and DN 2 of the Income Tax Act 2007 if the CFC is a non-attributing active CFC under section EX 21B of the Income Tax Act 2007 because the requirements of sections CQ 2(1)(h) and DN 2(1)(h) are not satisfied. Section EX 21B(3) of the Income Tax Act 2007 provides that a CFC is a non-attributing active CFC if it is an insurer that meets the requirements of section 91AAQ of the Tax Administration Act 1994 and the Commissioner makes a determination under that section. In the absence of such a determination, a CFC carrying on an insurance business is unlikely to be a nonattributing active CFC, because insurance income is otherwise treated as passive income and an attributable amount under section EX 20B(3) of the Income Tax Act 2007.

Description: A person has no attributed CFC income or loss from a CFC under sections CQ 2 and DN 2 of the Income Tax Act 2007 if the CFC is a non-attributing active CFC under section EX 21B of the Income Tax Act 2007 because the requirements of sections CQ 2(1)(h) and DN 2(1)(h) are not satisfied.

Description: A person has no attributed CFC income or loss from a CFC under sections CQ 2 and DN 2 of the Income Tax Act 2007 if the CFC is a non-attributing active CFC under section EX 21B of the Income Tax Act 2007 because the requirements of sections CQ 2(1)(h) and DN 2(1)(h) are not satisfied.

Description: A person has no attributed CFC income or loss from a CFC under sections CQ 2 and DN 2 of the Income Tax Act 2007 if the CFC is a non-attributing active CFC under section EX 21B of the Income Tax Act 2007 because the requirements of sections CQ 2(1)(h) and DN 2(1)(h) are not satisfied.

Description: The Arrangement is where a shareholder holds shares in a company and the shares were acquired for the purpose of disposal. Subsequently, the rights attached to the shares are altered and the following apply: The shares are in a company registered under the Companies Act 1993; The alteration is not structured as a cancellation and issue of shares.

Description: The Arrangement is where a shareholder holds shares in a company and the shares were acquired for the purpose of disposal. Subsequently, the rights attached to the shares are altered and the following apply: The shares are in a company registered under the Companies Act 1993. The alteration is not structured as a cancellation and issue of shares. After the alteration, the shareholder disposes of some or all of their shares with altered rights.

Description: This Interpretation Statement considers the income tax treatment of amounts of money or property transferred to New Zealand resident taxpayers by a person overseas, including through inheritance. It addresses how to determine whether the person who transfers the money or property is a trustee of a trust and when a taxpayer will have derived either beneficiary income or a taxable distribution from a foreign trust.

Description: This 'Question We've Been Asked' (QWBA) explains how the income tax rules apply if property held in a trust is rented out by a beneficiary of the trust for short-stay accommodation (eg, through Airbnb, Bookabach or Holiday Houses). The most common situation where it will be a beneficiary renting out a property held in trust is where the property is the beneficiary's family home.

Description: This 'Question We've Been Asked' (QWBA) explains how the income tax rules apply if property held in a trust is rented out by the trustees for shortstay accommodation (eg, through Airbnb, Bookabach or Holiday Houses). It will usually be the trustees renting out the property where the property is either a dedicated short-stay accommodation property, or a property that's sometimes rented out and sometimes used for other purposes (eg, it's used by beneficiaries of the trust).

Description: This Statement sets out the Commissioner-s practice for providing relief when the immediate payment of an overdue child support or domestic maintenance obligation is not possible. The relief is provided in the form of an agreement to pay the debt in instalments; writing off penalties in certain situations; or in limited circumstances, writing off part or all the child support debt.

Description: The Commissioner is aware that there has been significant uncertainty regarding whether employer-provided travel1 from home to a distant workplace is subject to income tax, so PAYE must be deducted, or to fringe benefit tax (FBT). This Statement addresses whether this type of travel is subject to tax and outlines the approach to the tax treatment in this area which the Commissioner will, on a prospective basis, accept as correct. To reduce uncertainty and foster taxpayer compliance, the Commissioner has deliberately sought to take a pragmatic approach as far as this is possible within the law.

Description: This is an appeal from a decision of the Taxation Review Authority ('TRA') regarding Mr Dowden's challenge to the Commissioner of Inland Revenue's ('Commissioner') PAYE, GST and INC assessments for tax periods between January 2004 and May 2012. These assessments concerned several businesses run by Mr Dowden, including Safeguard Security ('Safeguard'). Mr Dowden claimed to have transferred his interest in Safeguard to his former partner, Ms Jackson, in December 2003. Mr Dowden's case was that Ms Jackson was liable for tax relating to Safeguard between January 2004 and December 2011.

Description: This proceeding was a tax challenge in relation to reassessments made for six GST periods (from the tax year ended 31 March 2012 to the tax year ended 31 March 2015) to include payments that the disputant, CD Trust, has treated as not being subject to GST. The Taxation Review Authority ('the Authority') found for the Commissioner of Inland Revenue ('the Commissioner') and upheld the reassessments (during the preparation for the hearing the Commissioner's investigator identified that there were errors in the calculations underlying the assessments and recalculated what the correct amount of the assessments should be. The Taxation Review Authority varied the assessments accordingly pursuant to s 138P of the TAA.)

Description: The Court of Appeal dismissed P's appeal and accepted the Commissioner of Inland Revenue ('CIR') had acted correctly in changing P's child support entitlement to nil.