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	<title>TalkTax</title>
	<link>http://www.talktax.co.nz</link>
	<description>A Blog for Tax and Accountancy professionals</description>
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		<title>Imputation credits &amp; resident withholding tax – reminder</title>
		<description><![CDATA[As year-end is approaching quickly, it is important to remember that the maximum imputation ratio for dividends is 28:72 for the 2012 income year (previously 30-70 up to end of the 2011 income year).  The Resident Withholding Tax (RWT) rate on dividends remains at 33 cents in the dollar meaning dividends are still taxed [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2012/01/31/imputation/</link>
			</item>
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		<title>AIL and the interest exemption under the US and Australian DTAs</title>
		<description><![CDATA[In a world with virtually unconstrained capital flows, countries such as New Zealand with limited amounts of domestic saving are simply finding it impossible to make non-residents bear the cost of taxation on the fixed return they demand for lending money to New Zealand businesses.  The need to exempt non-residents does not explain, however, why it was necessary to add an additional 200 bps to the New Zealand borrower’s interest costs by imposing AIL on the NZ resident borrower.
]]></description>
		<link>http://www.talktax.co.nz/index.php/2012/01/24/ail-and-the-interest-exemption-under-the-us-and-australian-dtas/</link>
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	<item>
		<title>Tax efficiency in the spotlight</title>
		<description><![CDATA[New Zealand tax system has been ranked the 27th most efficient out of the 183 countries surveyed in a report compiled by PricewaterhouseCoopers, the World Bank and the International Finance Corporation.
New Zealand&#8217;s average tax rate of 34.4 compares favourably with the average global rate of 44.8 per cent, and Australia&#8217;s rate of 47.7 per cent.
New Zealand [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/11/23/tax-efficiency-in-the-spotlight/</link>
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	<item>
		<title>It&#8217;s happening everywhere ..</title>
		<description><![CDATA[An annual survey by the global accounting firm Ernst &#38; Young found tax authorities are becoming more aggressive and forcing companies and governments into more clashes over tax laws.   88% of large companies surveyed said managing tax risk and controversy would become even more important to them in the next two years.]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/11/22/its-happening-everywhere/</link>
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	<item>
		<title>Falls Road &#8211; when GST is not just part of the purchase price</title>
		<description><![CDATA[A recent HC decision has interesting implications for the payment of GST in property settlements that involve nominees.   In this case:
(a)    Fletcher agreed to sell land to the Hulls, who nominated Falls Road to complete the transaction.
(b)   The GST ($650k) was payable before settlement and so a GST invoice was issued by Fletcher and Falls [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/11/09/falls-road-when-gst-is-not-just-part-of-the-purchase-price/</link>
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		<title>Taxation of UK Pensions &#8211; Ignorance is bliss?</title>
		<description><![CDATA[The IRD have apparently indicated that audit and enforcement action against NZ tax residents with UK pensions will be suspended pending the outcome of a more general policy review of this area.  
]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/11/07/taxation-of-uk-pensions-ignorance-is-bliss/</link>
			</item>
	<item>
		<title>The perfect gift after 125 years</title>
		<description><![CDATA[An Inland Revenue report on the abolition of gift duty is set to cost professionals such as accountants and lawyers around $70 million in lost compliance fees. It is estimated that the government will save around $430,000 in administration fees but forego the $1 million a year in duty they were receiving from the scheme. [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/09/14/the-perfect-gift-after-125-years/</link>
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		<title>Law Society comments on Newmarket Trustees</title>
		<description><![CDATA[Although the Newmarket Trustees case appeal has yet to be heard, the Law Society has come out in support for the single corporate trustee model.
See http://www.adls.org.nz/about-adls/committees/public-issues-committee/public-issue-papers
Another advantage of the single or dedicated corporate trustee model is the ease (and cost effectiveness) at which the effective control of the corporate trustee can be changed.  However, [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/09/07/law-society-comments-on-newmarket-trustees/</link>
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		<title>GST-offsets &#8211; a lesson why not to</title>
		<description><![CDATA[The recent decision in Spicer v Boulcott Development Group Limited  HC Wellington CIV-2011-485-714, 24 August 2011 highlights the dangers inherent in GST-offset agreements.  Although these agreements will be less common with the amendment to the GST Act allowing zero-rating of land there are still occasions where GST-offset agreements may be contemplated.
The facts of [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/08/30/gst-offsets-a-lesson-why-not-to/</link>
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	<item>
		<title>Penny &amp; Hooper &#8211; legitimate tax planning or avoidance?</title>
		<description><![CDATA[The Supreme court has today released its long-awaited decision about a landmark tax case – Penny &#38; Hooper.  The case was decided in favour of Inland Revenue and this decision has widespread implications for the many small businesses using trust structures.
The case is a classic example of taxpayers complying with the ‘black-letter’ of the [...]]]></description>
		<link>http://www.talktax.co.nz/index.php/2011/08/24/penny-hooper-legitimate-tax-planning-or-avoidance/</link>
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