1. Jane is aged 67. She has owned and operated a clothing manufacturing business in Christchurch since 1998. Her son Nigel is now the managing director and effectively controls and operates the business. Jane owns a home in Ilam as well as one in Mooloolaba on the Australian Sunshine Coast.

Since retiring in 2020 and beginning to collect New Zealand superannuation, Jane has spent six months of each year in Mooloolaba and six months in Christchurch.

Jane receives dividends on shares in companies in Australia and the United Kingdom. She also has investments earning interest in New Zealand and Australia.

The New Zealand Superannuation and Retirement Income Act 2001 indicates a person is not entitled to receive superannuation unless they are ordinarily resident in New Zealand.

The Commissioner of Inland Revenue in New Zealand has indicated that she intends to assess Jane on all income earned by her in the last tax year.

REQUIRED:

Advise Jane if she has any grounds for challenging this by way of the dispute resolution process. (The dispute resolution process itself will be covered in our final lecture). Cite all relevant authorities. If there is more information you require from Jane, outline what that is and why it is important.