Foreign Equity Investments Flashcards
What is a controlled foreign company?
- Foreign Company
- < 5 NZ residents have control interest
- Single NZ resident has constrol>40% and no non-resident has greater control
CFC Rules?
Only attribute “Passive Income”
Amount remitted depends on income interest
Attributed CFC is assessable income
What are exemptions to the CFC rules?
Passive income <5% total income
Income interst in CFC <10%
Non- Attributing Aussie CFC
FIF income rules?
Attributing interest in FIF
No exemptions
Total interests >$50,000
What is an attributing interest?
Shares in a foreign company
Superannuation (Foreign)
Foreign life insurance
Fait Dividend rate (FDR) formula
(0.05 x Opening value) + quick sale adjustment
What is the quick sale adjustment
Lesser of Peak holding method
(0.05 x Peak holding x Average cost)
Quick sale gain
(Gain - (Interest x Average cost)
Corporate Value Method (CV) Method
FIF income = (Closing Value + Gains) - (Opening Value + costs)
What method does a natural person use?
If they elect to use CV, any loss will be set to zero,
If they must use it (Non ordinary shares),
can result in a loss