Commercial transactions

I provide tax advice in the context of commercial transactions:

Major transactions such as a sale and purchase of a business (equity or the business proper), entry or exit of business partners, sale and purchase of substantial assets, and merging or expanding existing business.

Or, “ordinary” transactions within the business such as how to treat one-off payments to key personnel, whether an amount is capital or revenue, whether an amount is deductible or taxable.

Business structuring

Structuring your business in the right way from the outset is imperative. I provide advice on which entity types to use depending on the type, nature, and scale of the business, how the “new entity” should be set up where this is part of a wider business structure, and how the structure should operate once established.

I provide tax advice on setting up business and investment structures in Australia (such as using limited liability partnerships), and investing in foreign jurisdictions via fiscally transparent entities to achieve a flow through of foreign tax paid. I have affiliates in Australia who are able to provide Australian tax and legal advice, and can deal with on-going Australian compliance.

I also conduct “health checks” of your existing business structures. I provide tax advice on the operation and tax effectiveness of structures already in place, and how to better any inefficiencies identified as part of this process. This could involve, for instance, restructuring or simplifying your structure.

Family transactions

Distribution, resettlement and reinvestment of family wealth that has been accumulated over the years gives rise to a myriad of tax issues.

I provide tax advice on how assets can be distributed between family members, where assets should sit within the investment structure, and setting up wealth retention and accumulation structures for the next generation.

Having a structure in place that meets the overarching succession objectives of the family is important. I provide advice on how to manage and monitor family asset and investment structures, as well as drafting legal documents to ensure that the structures are administered appropriately on an on-going basis.

International tax

I provide tax advice on the workings of double tax agreements, use of foreign tax credits, as well as advice on New Zealand international tax rules relating to business or investment interests held in foreign jurisdictions.

Binding rulings

With the need for greater certainty in tax, there has been an increase in requests for binding rulings. I have specialist expertise in preparing binding ruling applications and a strong working knowledge of how the binding ruling process works.

Binding rulings should be considered, for instance, when restructuring business affairs or entering into new business ventures, and when Inland Revenue confirmation that a transaction/structure is not a tax avoidance arrangement is considered prudent.

Tax disclosures, reviews and disputes

A good working relationship with Inland Revenue is important to resolve tax matters expediently. I work alongside my clients to consider practical issues such as when to make a disclosure, when to initiate a tax dispute, when to apply for a binding ruling and when purchasing tax is a good option.

I prepare voluntary disclosures, tax dispute documents, as well as dealing with Inland Revenue in relation to tax risk reviews, audits and the like.

Training and development

Professional development is an on-going process and I contribute to this cause as much as I am able. I provide tax and legal training sessions, at no cost, to professional bodies and networking groups. I also provide tailored tax training for firms – I can design sessions that address the development requirements of staff and can do these sessions as a lunch workshop, or formal setting. I am also available for panel discussions to provide a tax law perspective as required.

Tax compliance

While I do not prepare tax returns, I have strong affiliate accounting firms who are able to prepare tax returns. I personally review the compliance as required to confirm the tax position for my clients.

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