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  1. #31
    Ignorant. Just ignorant.
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    Also for IVV as mentioned above. . .

    Result: SPY
    The ASX Ticker Code you have entered relates to SPDR S&P 500 ETF Trust.

    Based on the information you have provided, your income for 1 April 2020 to 31 March 2021 does not qualify for the Australian share exemption.

    Other exemptions apply to certain ASX listed investments under certain circumstances. Please consult your accountant, tax advisor, broker, or the relevant investment fund.

    If the investment is a FIF, the income will generally be taxed under the:

    fair dividend rate (FDR) method
    comparative value (CV) method
    cost method (CM)
    deemed rate of return (DRR)
    You can find information about these methods on our website under Foreign investment funds

  2. #32
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    Xero does not qualify for the Australian exemption because as a New Zealand company it does not come under the FIF rules to start with, regardless of where or where not it is listed.

  3. #33
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    Quote Originally Posted by Nor View Post
    Xero does not qualify for the Australian exemption because as a New Zealand company it does not come under the FIF rules to start with, regardless of where or where not it is listed.
    More clarity needs to be given on IRD's website, specifically the exact wording what is FIF and what is not FIF and what is exempt from FIF (if they're foreign based or not?)

    If Xero re-established a new head quarters in Australia (ie how Burger King moved to Canada in the merger with Tim Hortin's Donuts), where would Xero fit in under FIF? One can't simply assume that if a company started out in NZ, and leaves ; where is the disclosure of this when a person looks at the IRD's FIF checker online to find it's status?

    Likewise if a foreign company chooses to establish a head quarters in NZ (ie. Restaurant Brands that holds NZ based fast foods such as KFC, Pizza Hut, Carl Jr) - these are clearly foreign brands but since they trade on the NZX, they are simply exempt from FIF.

    This is the kind of information that NZ financial advisors don't know and don't care to advise their clients. What % of the profits are gone abroad for say KFC despite they are FIF exempted as having a separate parent entity established in NZ. The complexities involved are mind boggling. If was is in Canada, my choice of buying a company on the TSX vs NYSE is very clear. We look at the corporate tax rates, and state / prov tax rates and that's pretty much about it. The individual investor pays CGT regardless if the shares were owned on the TSX or on the NYSE. (many Canadian companies enjoy dual listing Can / US).

  4. #34
    Reincarnated Panthera Snow Leopard's Avatar
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    Quote Originally Posted by SBQ View Post
    More clarity needs to be given on IRD's website, specifically the exact wording what is FIF and what is not FIF and what is exempt from FIF (if they're foreign based or not?)

    If Xero re-established a new head quarters in Australia (ie how Burger King moved to Canada in the merger with Tim Hortin's Donuts), where would Xero fit in under FIF? One can't simply assume that if a company started out in NZ, and leaves ; where is the disclosure of this when a person looks at the IRD's FIF checker online to find it's status?

    Likewise if a foreign company chooses to establish a head quarters in NZ (ie. Restaurant Brands that holds NZ based fast foods such as KFC, Pizza Hut, Carl Jr) - these are clearly foreign brands but since they trade on the NZX, they are simply exempt from FIF.

    This is the kind of information that NZ financial advisors don't know and don't care to advise their clients. What % of the profits are gone abroad for say KFC despite they are FIF exempted as having a separate parent entity established in NZ. The complexities involved are mind boggling. If was is in Canada, my choice of buying a company on the TSX vs NYSE is very clear. We look at the corporate tax rates, and state / prov tax rates and that's pretty much about it. The individual investor pays CGT regardless if the shares were owned on the TSX or on the NYSE. (many Canadian companies enjoy dual listing Can / US).
    If a Canadian person chooses to establish them-self in New Zealand should he learn to live with the local tax system instead of whining continuously about how it is better in some frigid snow bound foreign la-la-land where all is dried moose meat & maple syrup?



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  5. #35
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    Quote Originally Posted by SBQ View Post
    More clarity needs to be given on IRD's website, specifically the exact wording what is FIF and what is not FIF and what is exempt from FIF (if they're foreign based or not?)

    Likewise if a foreign company chooses to establish a head quarters in NZ (ie. Restaurant Brands that holds NZ based fast foods such as KFC, Pizza Hut, Carl Jr) - these are clearly foreign brands but since they trade on the NZX, they are simply exempt from FIF.

    This is the kind of information that NZ financial advisors don't know and don't care to advise their clients. What % of the profits are gone abroad for say KFC despite they are FIF exempted as having a separate parent entity established in NZ. The complexities involved are mind boggling.
    Short Answer

    RBD is an NZ company, and so is exempt from FIF for shareholders.


    Long Answer

    Restaurant Brands (RBD) operates -under licence- KFC, Pizza Hutt, and Taco Bell restaurants around the Pacific rim. RBD was floated on the NZX late last century by U.S headquartered Pepsico, who, at that time, owned what was to eventually become the separate listed entity 'YUM Brands!' (YUM). At the time of the RBD float, Pepsico reduced their holding in RBD to zero. RBD was not and never has been a 'headquarters' for any American entity. RBD may have been floated originally by the Americans. But it has been an NZ company from day 1.

    The restaurant concepts you talk about are owned by master franchise holder 'YUM Brands!', which is a US registered company (except for Carls Junior which is franchised from another U,S corporation) . RBD has only ever owned the restaurants, or leases to the restaurants. RBD have never owned the brands KFC., Pizza Hut and Taco Bell, under which monikers the restaurants trade. YUM only owns a few restaurants themselves. In the case of KFC, 99% globally are franchised.

    YUM generally earns money by taking a percentage of the turnover of those KFC/ Pizza Hut / Taco Bell restaurant owners from around the globe that have licensed their restaurant concepts. RBD is a bit shy as to what the franchise fee they pay to YUM each year is (I think they have a confidentiality agreement that may mean they cannot disclose it). But disclosure from similarly listed restaurant owning companies that operate the KFC, Pizza Hut and Taco Bell concepts overseas would suggest the franchise fee is around 5% of turnover. That isn't straight profit for YUM. YUM provide marketing support, product development, training manuals and, in the case of KFC, shipments of the top secret 11 herbs and spices that give KFC its globally repeatable flavour. The franchise fees are are part of the 'Cost of goods sold' that is not broken down in the RBD financial statements. But if my estimate of a franchise fee of 5% of sales is correct:

    0.05 x $892.359m = $42.6m

    The franchise fees are roughly equivalent to the normalised profit that RBD made last year, so are very substantial.

    The fact that Mexican owned 'Global Valar S.L.' now own 75% of RBD makes RBD a foreign controlled New Zealand company. But it doesn't change the fact that RBD is a New Zealand company, even though 75% of profits now go off shore. So you see, once you know the background story as to how RBD works, the tax situation becomes clear. I sincerely hope your mind is now 'unboggled' on RBD, SBQ.

    SNOOPY

    discl: I know all this because I am a foundation RBD shareholder, I still own shares in both RBD and YUM, and I make my FIF declaration relating to my ownership of YUM annually
    Last edited by Snoopy; 08-07-2021 at 06:59 PM.
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