Cross-border Tax Advisory Services
Relocating from the United States to New Zealand, or investing here, brings exciting opportunities. But it can also become very complex.
New Zealand’s tax system is fundamentally different from the US. Add in US worldwide taxation, FATCA obligations, foreign trusts, controlled foreign corporations, and double tax agreements, and careful planning becomes essential. At McCulloch & Partners, we provide specialist international tax advice for large and small transactions to US citizens, green card holders, investors and families navigating cross-border tax between the United States and New Zealand.
Meet Our Advisors
Dr Benjamin Walker
Dr Ben Walker is a New Zealand-based international tax partner specialising in advising high-net-worth individuals, investors, and globally mobile families on cross-border structuring and relocation.
He works extensively with U.S. clients moving to New Zealand, providing clear, commercially focused advice on tax residency, transitional resident rules, trust and investment structuring, and managing multi-jurisdictional tax exposure. Ben is known for cutting through complexity to deliver practical outcomes, ensuring clients can move and invest with confidence while remaining fully compliant across New Zealand, the United States, and other jurisdictions.
Professor Craig Elliffe
Professor Craig Elliffe is New Zealand’s leading international tax expert and brings an unparalleled level of experience to McCulloch & Partners. A Professor of Taxation Law at the University of Auckland Law School, Craig is a former partner at KPMG and Chapman Tripp, and has over 30 years of experience advising on complex domestic and international tax matters.
He is widely recognised for his contributions to New Zealand’s tax system — having served as a member of the Tax Working Group, and as an advisor to the OECD and Inland Revenue on international tax reform. His research focuses on corporate taxation, international tax, and the integrity of the tax base, and he has authored leading texts including International and Cross-Border Taxation in New Zealand and The Taxation of Trusts. Craig completed his PhD at the prestigious Cambridge University.
We Guide You Through:
Residency
& Tax Status
If you become NZ tax resident, which of your foreign assets and income will come into the tax system?
Foreign Investment
& Assets
How to structure overseas investments, trusts, shares, or businesses before and after arrival.
Transitional Relief
& Safe Harbours
Whether you can mitigate or defer tax on pre-migration gains or balances.
Trusts, Estate
& Succession Planning
How to manage or restructure family trusts and inheritance in light of NZ rules.
Double Tax Agreements
& Foreign Tax Credits
How to use NZ’s tax treaties and foreign tax credit regime to avoid double taxation.
Ongoing Compliance
& Reporting
Ensuring continuous compliance: disclosures, filings, and planning as your situation evolves.
FAQs
Will I become a New Zealand tax resident if I purchase a property?
Short answer: Potentially.
You become tax resident if you are in NZ for 183+ days in a 12-month period or establish a “permanent place of abode” (PPOA).
How we help:
We plan when and how residency is triggered to maximise tax efficiency—particularly to access the transitional resident regime.
What is the transitional resident exemption?
Short answer: A major tax benefit.
If you qualify, most foreign-sourced income (including U.S. investments, trusts, and business income) can be exempt from NZ tax for up to ~4 years.
How we help:
We structure your arrival and assets to fully utilise this window and avoid accidentally losing it early.
Will I still pay U.S. tax?
Short answer: Yes.
As a U.S. citizen/green card holder, you remain taxable in the U.S. on worldwide income regardless of where you live.
How we help:
We coordinate NZ and U.S. positions to avoid double taxation and align with the New Zealand–United States Double Tax Agreement.
How are my U.S. investments taxed in New Zealand?
Short answer: It depends on the asset.
Shares/funds may fall under NZ’s FIF regime
Trusts and LLCs can have complex treatment
Retirement accounts (IRAs/401(k)s) have specific rules
How we help:
We review your portfolio and restructure where needed before you become taxable in NZ.
What happens to my IRA or 401(k)?
Short answer: Timing is critical.
During the transitional period, withdrawals may be exempt in NZ. After that, NZ tax can apply—even if tax-free in the U.S. (e.g., Roth IRA).
How we help:
We plan withdrawal timing and long-term strategy to minimise NZ tax leakage.
Who are McCulloch & Partners?
McCulloch & Partners is a well-established New Zealand advisory firm with a long history of providing specialist tax and structuring advice to high-net-worth individuals, families, and international investors. The firm is privately owned and independent, with no affiliation to investment funds, banks, or product providers—ensuring that all advice is genuinely objective and aligned solely with client outcomes.
The practice is led by senior professionals with deep expertise in cross-border tax, particularly involving New Zealand, the United States, Australia, and Europe. The firm regularly advises on complex matters including relocation, tax residency, inbound investment structuring, trusts, and multi-jurisdictional wealth planning. It is known for delivering clear, commercially focused advice in situations where multiple tax systems intersect, and where getting the structure right upfront is critical.
For U.S. investors coming to New Zealand under the Active Investor Plus Visa or otherwise, this combination of independence and technical depth is particularly valuable. The firm works closely alongside clients’ existing U.S. advisors to ensure positions are aligned across both jurisdictions, while also providing hands-on guidance through the practical realities of investing and living in New Zealand.
Speak With an International Tax Specialist
If you are relocating to New Zealand or investing here from the United States, speak with us to streamline the process and get expert advice.