Articles
Two Tribes and an Elephant Called Ben Nevis – Tax Avoidance – September 2009
Two Tribes and an Elephant Called Ben Nevis – September 2009 The tax avoidance provision, section BG 1 Income Tax Act 2007 (“ITA 2007”) first
Judicial Review? No Thanks! – July 2009
Judicial Review? No Thanks! – July 2009 MIKE LENNARD, Tax Barrister In this article, Mike Lennard looks at the historically unsuccessful attempts by various taxpayers
Search Powers Under Scrutiny – March 2009
Search Powers Under Scrutiny – March 2009 Nicholas Petroulias, a former Assistant Commissioner in the Australian Tax Office, fell from grace in spectacular fashion in
What’s Mine is Yours – A New Dimension to Section 157 – December 2008
What’s Mine Is Yours – Section 157 Notices – December 2008 What’s Mine Is Yours – A New Dimension to Section 157 Most tax practitioners
Deemed Correctness in Time-Barred Years – November 2008
In the recent High Court decision McIlraith v CIR (2007) 23 NZTC 21,456, Asher J held that the CIR could amend the current account balance carried forward from
Taxing but Interesting – Deductibility of Interest on Unpaid Tax – October 2008
Taxing but Interesting Tax is an inevitable part of doing business. Even with the changes to align provisional tax payments more closely with GST, it still
A Walk on the Wild Side – Bizarre Tax Arguments – September 2008
A Walk on the Wild Side Challenges to tax assessments usually challenge either the correctness of the assessment (carried on, almost entirely, through the Part
How Long to Resolution? – Delay in Tax Disputes – August 2008
How Long To Resolution? “Justice delayed is justice denied.” William Gladstone, British politician (1809 – 1898) Introduction It is often said that the introduction of revised
Whoops, Wrong Section – Misdescribing the Section – July 2008
Whoops, Wrong Section! – July 2008 “If the exercise of a power can be traced to a legitimate source the fact that the same was
How Secret are the CIR’s Squirrels? – IRD Secrecy Obligations – June 2008
Section 81 Tax Administration Act 1994 (TAA 1994) provides a principle of confidentiality of taxpayer information which is, as recognised in s 6 TAA 1994,
Rabbits from Hats – Defects in Evidence Exclusion – May 2008
The “Evidence Exclusion Rule” in s 138G Tax Administration Act 1994 (TAA 1994) is designed as a “key part” of the disputes resolution procedure[1],’ and
Detention and Non-Disclosure – Questions about Inquiries – April 2008
Section 19 Tax Administration Act 1994 (TAA 1994) enables the CIR to hold an inquiry by requiring any person to attend at an Inland Revenue