Without a controlled foreign company regime, taxpayers can establish companies in other countries to trap foreign-source income or accept income diverted from domestic sources. At one extreme, a regime may cover all foreign jurisdictions. At another, it may cover only tax havens. Some countries...

The New Zealand tax system allows the possibility of double taxation through the mis-matching of characterisations of business and investment entities in a large number of circumstances. However, practical problems are uncommon. To avoid difficulties, the principle of private international law...

For any country, working out the most appropriate method of taxing its residents' interests in foreign investment funds poses difficult challenges of regime design. Unlike some problems of tax design, the optimum structure of a foreign investment fund regime is likely to vary with the size of...