- When a beneficiary of a trust owning shares in an LTC gets a distribution, this gives rise to an additional person in the number of owners test. 3 years is to become 6.
- Losing LTC status if a trust shareholder makes a distribution to a company.
- Charities and Maori authorities cannot be shareholders in LTCs.
- Can have more than 1 class of shares and different voting rights.
- Foreign income when more than 50% of LTC shares held by non resident limited to greater of 20% or $10000.
- Get rid of loss limitation rule except where there are partnerships of LTCs. ? Deductions carried forward are to be claimable in 2018 year.
- Anti avoidance S GB 50 dealing with transactions with shareholders at less than market value to apply.
- No debt remission income if debt to shareholder cannot be repaid by LTC.
- No more transferring a company to LTC and dodging the extra dividend withholding tax.
From 1 April 2017, there are to be major changes/improvements to the LTC regime including: