The five draft rulings consider the New Zealand tax consequences for a New Zealand investor in a United States limited liability company (US LLC) under five scenarios:

• The investment is a foreign investment fund (FIF) and the total cost of all the New Zealand resident investor’s attributing interests in FIFs is $50,000 or less. 
• The investment is a FIF and dividends are derived by the New Zealand resident investor. 
• The investment is an attributing FIF interest and dividends are derived by the New Zealand investor. 
• The investment is an interest in a controlled foreign company (CFC) giving rise to attributed CFC income and dividends are derived by the New Zealand resident investor.
• The investment is either a non-attributing active FIF or a non-attributing active CFC and dividends are derived by the New Zealand investor.

The draft rulings are a reissue of BR Pub 20/01 – 20/05. The conclusions have not changed.

CA ANZ support the proposed reissue of the rulings.