http://www.ird.govt.nz/yoursituation-bus/bus-aust-nz/tax-basics/comp-inctax/

And to add to Geoff very astute comment, an international wrinkle.
Shares are essentially discounted cash-flow of future profits
(expected margin between revenue and costs). NZ has ZERO capital gains
tax (for the moment assuming govt doesn't loses sanity). Also under
certain circumstances for a licensing trust, it imposes NO TAXES on
overseas revenue (passthrough entity). You can have a NZ trust, and
Australian operating company with final destination of the dividends
in ... say HK with its low marginal personal tax.

Yes, it's non-trivial (my client is planning on establishing multiple
master licenses around the world given his market is potentially in
the billions) but once established, it can be very efficient. Since
the startup costs are high (international tax lawyers are NOT cheap)
the only way it would  be cost-effective for SiliconBeachAustralia
participants is a once-off establishment fee (say for domain of Cloud
Computing) with sub-trusts for IaaS, PaaS, SaaS plays and pool
together all the IP (with pro-rata units granted to each company that
contributes). Then once the unit trust with licensing revenue is well
established, it can be listed for liquidity.

As always, personal circumstances vary and always seek professional
advice when undertaking complex transactions.

Lawrence
http://nz.linkedin.com/in/drllau
On Feb 21, 8:35 am, "Geoff McQueen | AffinityLive"
<geoff.mcqu...@affinitylive.com> wrote:
> another option, which has setup costs, is to establish a unit trust which
> owns the shares, and the company lends the trust money to buy them, which
> means no tax liability anywhere. then employees are provided with units in
> the unit trust, which are effectively stapled to the shares. when they
> vest, and employee sells them, then they have a tax liability, but at least
> they have the $$$ in their hands to pay the tax man.
>
> On Sun, Feb 19, 2012 at 23:06, Kev 
> <social%melon.com...@gtempaccount.com>wrote:
>
>
>
>
>
>
>
>
>
> > I chatted with an accountant and lawyer about this recently too.
>
> > Yes you are correct vesting shares can leave the shareholder with a
> > tax liability.  Apparently this differs to the US (I am unfamiliar
> > with what the tax impact is in the US for this scenario).
>
> > Apparently one way around it is to provide all the shares upfront, but
> > articulate in the shareholder agreement a buy back formula should the
> > shareholder leave/be fired etc.
>
> > Another way around it that was suggested to me is to spell out some
> > contribution towards the tax liability by the company after all the
> > shares have vested and at the time of a liquidity event.
>
> > Hope this helps.
>
> > Kevin
>
> >http://twitter.com/ke_ga
>
> > On Feb 19, 11:21 pm, Michael Overell <michael.over...@gmail.com>
> > wrote:
> > > Do delayed vesting shares leave founders with personal tax
> > > liabilities?
>
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> --
> *Geoff McQueen*
> CEO
> <http://www.affinitylive.com/?utm_source=signature&utm_medium=email&ut...>
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>
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