title: Taxation of gains from banking and insurance businesses in New Zealand

authors: Manyam, Joel

subjects: income tax

abstract: There has been major contest over the taxation of business income. Questions are twofold: the factual one of defining the boundaries of the business activity. Second, that of determining whether a particular gain comes within the ambit of ‘business’.
Recent NZ cases have sought to apply the guiding principle - that it is not the size of the gain but the source of it that determines the taxation consequences.
Logically, this principle should apply to specialist businesses such as those dealing with banking and insurance. However, the NZ Commissioner has, until 10 years ago, argued that it is the size rather than the source of the gain that is the determining criterion. And since the questions of what is the scope of the particular business activity and whether the particular gain has arisen in the course of such activity are purely factual ones, they are to be guided by the facts of each case.
This article concludes that the decisions are indeed based on their particular facts. Further, it investigates how important it is for the taxpayer to ponder the strategy that is to underpin the particular business. The evidence of such strategy being in place and having the practical effect of guiding the decision making of the taxpayer company’s business activities are highly significant in determining the taxation consequences of such decision making. The consistency with which such corporate strategy or policy is formulated and implemented tends to determine their taxation consequences.

text: Taxation of gains from banking and insurance businesses in New Zealand There has been major contest over the taxation of business income. Questions are twofold: the factual one of defining the boundaries of the business activity. Second, that of determining whether a particular gain comes within the ambit of ‘business’.
Recent NZ cases have sought to apply the guiding principle - that it is not the size of the gain but the source of it that determines the taxation consequences.
Logically, this principle should apply to specialist businesses such as those dealing with banking and insurance. However, the NZ Commissioner has, until 10 years ago, argued that it is the size rather than the source of the gain that is the determining criterion. And since the questions of what is the scope of the particular business activity and whether the particular gain has arisen in the course of such activity are purely factual ones, they are to be guided by the facts of each case.
This article concludes that the decisions are indeed based on their particular facts. Further, it investigates how important it is for the taxpayer to ponder the strategy that is to underpin the particular business. The evidence of such strategy being in place and having the practical effect of guiding the decision making of the taxpayer company’s business activities are highly significant in determining the taxation consequences of such decision making. The consistency with which such corporate strategy or policy is formulated and implemented tends to determine their taxation consequences.

year: 2010

title: Stratigraphy and sedimentology of conglomerates in the Kidnappers Group, Hawke’s Bay

authors: Kamp, Peter J.J.

abstract: The Middle to Late Pleistocene Kidnappers Group comprises 400 m of diverse lithologies deposited in fluvial, marginal marine and shallow marine environments. The stratigraphy and sedimentology of the greywacke conglomerates, the dominant lithology in the group, is investigated, in part using three new computer programmes. 
Five environmentally sensitive lithologies are recognised: Lithotype 1 - Imbricated, inverse to normally graded conglomerate; Lithotype 2 - Planar cross-stratified conglomerate; Lithotype 3 - Thin, massive to stratified conglomerate; Lithotype 4 - Planar cross-stratified, shelly, sandy conglomerate; Lithotype 5 - Thin, massive to low-angle cross-stratified, shelly conglomerate.
On the basis of cross-stratification types, fossil content and the shapes, orientation fabrics and grain-size analyses of clasts, Lithotypes 1, 2 and 3 have a braided fluvial origin and Lithotypes 4 and 5 a shallow marine origin. Differences between Lithotypes 1, 2 and 3 identify a proximal-distal sequence within the braided fluvial environment. 
Lithotype 1 is interpreted as proximal channel and longitudinal bar facies, Lithotype 2 as mid-reach transverse and longitudinal/diagonal bar facies, and Lithotype 3 as channel and topstratum overbank deposits in the distal reaches of a braided river system.
From the vertical succession of conglomeratic facies and marine fossiliferous units, a chronology of submergence and emergence events in the Kidnappers Group has been established. This succession is dominantly controlled by glacio-eustatic fluctuations in sea level which agree in frequency and period with sea level fluctuations derived from deep sea core data from 0.5 to 0.1 m.y.B.P. Tectonism has also influenced the supply of sediment to the group and reinforced the magnitude of the submergence and emergence events.

text: Stratigraphy and sedimentology of conglomerates in the Kidnappers Group, Hawke’s Bay The Middle to Late Pleistocene Kidnappers Group comprises 400 m of diverse lithologies deposited in fluvial, marginal marine and shallow marine environments. The stratigraphy and sedimentology of the greywacke conglomerates, the dominant lithology in the group, is investigated, in part using three new computer programmes. 
Five environmentally sensitive lithologies are recognised: Lithotype 1 - Imbricated, inverse to normally graded conglomerate; Lithotype 2 - Planar cross-stratified conglomerate; Lithotype 3 - Thin, massive to stratified conglomerate; Lithotype 4 - Planar cross-stratified, shelly, sandy conglomerate; Lithotype 5 - Thin, massive to low-angle cross-stratified, shelly conglomerate.
On the basis of cross-stratification types, fossil content and the shapes, orientation fabrics and grain-size analyses of clasts, Lithotypes 1, 2 and 3 have a braided fluvial origin and Lithotypes 4 and 5 a shallow marine origin. Differences between Lithotypes 1, 2 and 3 identify a proximal-distal sequence within the braided fluvial environment. 
Lithotype 1 is interpreted as proximal channel and longitudinal bar facies, Lithotype 2 as mid-reach transverse and longitudinal/diagonal bar facies, and Lithotype 3 as channel and topstratum overbank deposits in the distal reaches of a braided river system.
From the vertical succession of conglomeratic facies and marine fossiliferous units, a chronology of submergence and emergence events in the Kidnappers Group has been established. This succession is dominantly controlled by glacio-eustatic fluctuations in sea level which agree in frequency and period with sea level fluctuations derived from deep sea core data from 0.5 to 0.1 m.y.B.P. Tectonism has also influenced the supply of sediment to the group and reinforced the magnitude of the submergence and emergence events.

year: 1978

title: Talking together: The effects of traditional Māori Pedagogy on children’s early literacy development

authors: Derby, Melissa

abstract: This article presents findings from a project that sought to determine the effects of a home-based literacy intervention on bilingual (English and Te Reo Māori) preschool children’s early literacy skills. The culturally responsive intervention, which was adapted from Tender Shoots, incorporated traditional Māori teaching and learning approaches, such as the use of storytelling, songs, games, and reminiscing about the past, as practices for supporting key cognitive skills crucial to foundational literacy, specifically phonological awareness and vocabulary knowledge. Over a 12-week period, during which the intervention was conducted, data were gathered from eight Māori preschool children and their families. The study utilised a crossover design. Four children and their families participated in the Rich Reading and Reminiscing (RRR) component of the intervention, which ran for six weeks, followed by the Strengthening Sound Sensitivity (SSS) portion of the intervention. The remaining four children completed the intervention in the reverse order of delivery. The crossover approach established a control in the study and allowed the effects of each part of the intervention on the aforementioned cognitive skills to be more clearly revealed. Overall, the data indicate that traditional Māori pedagogical practices helped to strengthen the early literacy skills of the children participating in the study.

text: Talking together: The effects of traditional Māori Pedagogy on children’s early literacy development This article presents findings from a project that sought to determine the effects of a home-based literacy intervention on bilingual (English and Te Reo Māori) preschool children’s early literacy skills. The culturally responsive intervention, which was adapted from Tender Shoots, incorporated traditional Māori teaching and learning approaches, such as the use of storytelling, songs, games, and reminiscing about the past, as practices for supporting key cognitive skills crucial to foundational literacy, specifically phonological awareness and vocabulary knowledge. Over a 12-week period, during which the intervention was conducted, data were gathered from eight Māori preschool children and their families. The study utilised a crossover design. Four children and their families participated in the Rich Reading and Reminiscing (RRR) component of the intervention, which ran for six weeks, followed by the Strengthening Sound Sensitivity (SSS) portion of the intervention. The remaining four children completed the intervention in the reverse order of delivery. The crossover approach established a control in the study and allowed the effects of each part of the intervention on the aforementioned cognitive skills to be more clearly revealed. Overall, the data indicate that traditional Māori pedagogical practices helped to strengthen the early literacy skills of the children participating in the study.

year: 2023-02