But Michael’s influence, the editors say, has gone beyond his teaching: “I would not have considered going to Dubai, moving to New York, or finally taking up a place at Cambridge in 2015 without Michael’s influence”; “Michael’s impact also arises through the more holistic care (for want of a better term) he provides to his students”; “I am one of the lucky many who has benefited from Michael’s enduring support. That support has played a substantial role in almost all of the most significant events in my recent academic and professional life”; “I first met Michael Littlewood in 2006.
Since then, his classroom instruction, advice, and friendship have had a major impact on the trajectory of my life. I feel some combination of gratitude and amazement as I contemplate how differently the past few years would have unfolded had Michael decided, all those years ago, not to return to New Zealand to teach at the University of Auckland. More bewildering, however, is that he seems to have had an equal if not greater impact on the lives of so many other students as well”.
The book consists of 18 chapters, one by each of the four editors and the others by 14 of Michael’s other students. Each chapter is based on a student paper written under Michael’s supervision. All of the chapters have been previously published – most in either the New Zealand Journal of Taxation Law and Policy or the Auckland University Law Review. Others, however, were published in other journals – the British Tax Review, the Hong Kong Law Journal, the New Zealand Universities Law Review and the Waikato Law Review.
Collectively, the papers cover a broad range of tax scholarship, from the highly technical to broad questions of policy. The first group of papers deal with new Zealand domestic tax: the tax consequences of surrendering an option (Phil Norton); fiscal responsibility (Chye-Ching Huang); whether it would be a good idea to increase the tax on liquor so as to curb binge drinking (Patricia Ieong); and the merits of allowing income splitting (Alice Jingjing Wang). Two chapters are on avoidance – one on the perennially troublesome distinction between unacceptable tax avoidance and acceptable tax planning (James Ruddell); the other on how the Commissioner of Inland Revenue should go about reconstructing arrangements found to be abusive (Tom Faulls).
A number of the papers concern international tax and double tax treaties (or DTAs) – one each on the New Zealand/Canada DTA (Sabrina Muck); treaty shopping (Louisa Boyd); China’s evolving tax treaty policy (Joanna Khoo); the tax treatment of suppliers of “independent personal services” (Keefe Han); and DTAs with tax havens (Kyle Rainsford). Another deals with the tax treatment of New Zealand firms’ offshore subsidiaries (Sehj Vather). Half a dozen of the papers add to the evolving literature on tax history: New Zealand’s first experiment with income tax in 1842 (Ogy Kabzamalov); the introduction of stamp duty and estate duty in New Zealand in 1866 (Aditya Basrur); the more successful attempt at an income tax in 1891 (Luke Facer); the tax treatment of companies in New Zealand from 1840 to 2008 (Annie Steele); the tax treatment of married women (Nicola Jones); and, finally, the introduction of income tax in India in 1860 (Chris Jenkins).
As indicated by the book’s title, the papers were written over a span of ten years; where appropriate, however, they have been updated so as to retain relevance. As one of the editors observes, “The articles alone are impressive. Combining them allows the reader to view the subject over a broader arch: comparing local and international perspectives, contrasting theory, history, and practice.”