investments

By dwpv, 28 November, 2015

When the holder of a life insurance policy fell into arrears on the payment of premiums, the taxpayer was entitled to charge the cash surrender value of the policy with the amount of the arrears plus accrued interest thereon, such amounts being a first charge on monies payable under the policy. In finding that the interest was "income from investments of any kind other than investments in or on land" for purposes of the Land and Income Assessment Act, 1900 (New Zealand) Edwards J.

By dwpv, 28 November, 2015

Greene M.R. found that royalties derived by the taxpayer from the licensing of patents covering improvements in electrically operated hand tools were profits of its trade or business, rather than income from the holding of investments, in light of the relation of the patents to its business and the fact that it did not receive the royalties as a "mere passive owner". He also doubted the test of Macnaghten J. in C.I.R. v. Rolls-Royce, Ltd. (No.