A trustee is in principle liable to tax on trust income because the trustee is the legal owner of that income. Local source income is taxed in any event on a source basis, and foreign-source income is taxed to the trustee on a residence basis. In New Zealand, foreign source income is not taxed...

“Ectopia” is a label given here to a feature of tax law that distinguishes it from most other forms of law. Income tax law is dislocated from the facts to which it relates. This dislocation leaves a gap, or “ectopia” between tax laws and the economic facts of the transactions or...

The inheritance tax system in New Zealand revolves around an estate duty, levied on deceased estates and a gift duty on inter vivos gifts. There is no capital gains tax. The Estate and Gift Duties Act 1968 does not contain any general anti-avoidance provisions. Avoidance of duty is common....