بازار خرید و فروش انواع پارچه | پارچه سرا قیمت، خرید، فروش انواع پارچه
Limited partnerships are subject to the Limited Partnerships Act 2008 and must be registered with the New Zealand Companies Office. The name of a limited partnership must contain the words “limited partnership” or the abbreviation “LP” or “L.P.” at the end of the name. There are similar restrictions to companies. Given that full tax treatment of losses under a partnership will continue to be possible, the imposition of the loss limitation rule on the QCA would result in increased inconsistency in the tax treatment of narrow-knit corporations and partnerships. As noted above, such inconsistencies do not further the purpose of the quality control regime, which is to effectively tax closely owned companies as if they were complementary partnerships. The author believes that the time would be right to redefine this objective. Given that the QC has never offered direct tax treatment of losses, the plan`s objective seems too ambitious. The intent of the quality control regime should be to create a tax system that provides comparable tax benefits to small business owners, whether they operate through a corporation or partnership. The implications of the proposed SQ are far-reaching. Limiting losses under the SQ will limit the future of the LAQC. Indeed, the LAQC, since it has no loss limit, could be used to circumvent the LP`s loss limitation rule through entity shopping or a basic structuring mechanism. To avoid this, the LAQC should also be subject to the loss limitation rule or eliminated.
There are some notable problems with the LAQC. It does not achieve its stated objective and is strongly linked to tax evasion schemes. Although they are closely substitutable, LAQC and LP are not a perfect replacement. The LAQC serves a single purpose for managers-owners of narrowly held companies. The abolition of the LAQC on grounds of contestation cannot be justified. In a relatively old report, the CRQ noted that while the removal of a structure could be justified because it was used for tax evasion purposes, it would be necessary to abolish businesses, charities, trusts and partnerships. [169] If the proposed lp loss limitation rule comes into force, the most appropriate option would be to subject the LAQC to the same rule while addressing its tax avoidance issues by addressing its existing legislation. It would also be a good time to redefine the purpose of the quality control regime so that it can be achieved. Limited partnerships offer clients and investors the protection offered by limited liability status, which comes with the benefits of transparent tax status. Transparency is achieved by distributing the income of a partnership to one of the partners according to the share of the partners.
If a partner is not a resident of New Zealand and the income does not come from New Zealand, the partner will not be taxed. This makes New Zealand LPs particularly attractive to international clients, as they offer a tax-neutral investment space. [68] The new rules apply to New Zealand partnerships, limited partnerships and resident members of foreign partnerships and certain foreign limited partnerships. Existing special partnerships may choose to apply the new rules or continue to apply the existing rules until they expire or are dissolved. In some cases, it will be fair that not all losses are eligible for the tax deduction. However, there is “an inappropriate premise for denying a business loss simply because it was financed by borrowing and not by the investor`s own savings.” [113] The problem with the rule is that in a large number of cases, regardless of how the investment is financed, the losses will be “real.” When an asset loses value even if the money is borrowed, the investor actually pays to borrow the funds. The investor therefore accepts a real economic loss, i.e. the loss in value of the asset. If these losses cannot be claimed until the investment has brought gross income to the limited partner, there may be no incentive to invest, particularly in high-risk investments that are common in the venture capital industry and by their very nature cannot actually generate returns. .
