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Last edited by NZ Policy Webmaster
February 24, 2022 | History
A Government consultation document on the implications of company law changes for income tax rules in the various Revenue Acts.
It covers:
-
share repurchases and related issues
-
amalgamations
-
tax accounting issues,and
- other miscellaneous issues.
It also includes draft legislation and explanatory notes.
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Buy this book
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Subjects
taxation, new zealand, company tax, income tax, share repurchases, amalgamations, tax accounting issuesPlaces
New ZealandTimes
1993Showing 1 featured edition. View all 1 editions?
Edition | Availability |
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1
The taxation implications of company law reform: a discussion document
1993, New Zealand Government
Paperback
in English
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Libraries near you:
WorldCat
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Book Details
Table of Contents
CONTENTS.
PART ONE.
CHAPTER 1: OVERVIEW.
1
1.1 Purpose of the Discussion Document.
1
1.2 Submissions.
1
1.3 Background.
2
1.4 Objective and Scope of this Review.
2
1.5 Outline of the Document.
3
CHAPTER 2: SHARE REPURCHASES AND RELATED ISSUES.
9
2.1 Background.
9
2.2 General Considerations.
9
2.3 Current Rules for Taxing Share Cancellations.
11
2.4 Proposed Changes.
13
2.5 Mechanism for Taxing the Dividend Component of Share.
19
2.6 Treasury Stock Option.
24
2.7 Summary of Proposals.
24
Annex 2.1 Current Rules for Calculating Paid-Up Capital, Qualifying Share Premium and Excess Return Amount.
26
Annex 2.2 Mechanisms for Taxing the Dividend Component.
28
Annex 2.3 Examples of Mechanisms for Taxing the Dividend Component.
29
CHAPTER 3: AMALGAMATIONS.
31
3.1 Introduction.
31
3.2 The Amalgamation Provisions of the New Companies Act.
31
3.3 Tax Treatment of Revenue Account Shareholders in an Amalgamation.
32
3.4 Tax Treatment of Asset Transfers.
33
3.5 Losses and Imputation Credits.
34
3.6 Conclusion.
37
3.7 Summary of Proposals.
38
CHAPTER 4: TAX ACCOUNTING ISSUES.
39
4.1 Introduction.
39
4.2 Treatment of Company Accounting Reserves for Tax Purposes.
39
4.3 Amalgamations.
43
4.4 Excess Distributions.
44
4.5 Summary of Proposals.
45
Annex 4.1 Application of Tax Accounting Rules to an Amalgamation.
47
CHAPTER 5: MISCELLANEOUS ISSUES.
49
5.1 Introduction.
49
5.2 Capital Structure: Abolition of Nominal and Par Value.
49
5.3 Measurement of Shareholder Interests.
50
5.4 Abolition of Private and Public Company Distinction.
52
5.5 Proprietary Companies.
53
5.6 Companies Act References.
53
5.7 One Shareholder/One Share Companies.
54
5.8 Company Constitutions: Abolition of Memoranda and Articles of Association.
54
5.9 Other Terminology Changes.
54
5.10 Commissioner's Status as Preferred Creditor.
56
5.11 Summary of Proposals.
57
Annex 5.1.
58
Annex 5.2.
60
Annex 5.3.
62
Annex 5.4.
64
Annex 5.5.
66
Annex 5.6.
67
Annex 5.7.
69
PART TWO.
EXPLANATORY NOTES TO DRAFT LEGISLATION.
71
DRAFT LEGISLATION.
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