New Zealand Court Holds Resident May Claim China Tax Sparing Credit for CFC

A recent decision of the High Court of New Zealand has been published concerning whether a New Zealand resident is eligible to claim a tax sparing credit granted in China to that resident's controlled foreign corporation (CFC). The case involved a New Zealand resident individual that held a 30% stake in two Chinese companies that were deemed CFCs for New Zealand tax purposes. As such, income of the two companies was attributed to the resident, although no income was ever received. The income…