Saha v Commissioner of Inland Revenue - [2010] 3 NZLR 796

Revenue — Income tax — Foreign investment fund rules — Former partner in business becoming employee of foreign-owned purchaser of business — Former partners allocated shares in employer — Shares to be released progressively over five years and unreleased shares forfeit if former partner left employment — Taxpayer leaving employment by agreement and retaining half of unreleased shares — Taxpayer claiming deduction for forfeit shares — Whether forfeit shares disposed of for no consideration — Whether any gain derived in respect of forfeit shares — Income Tax Act 1994, ss CG 14(2), CG 18 and CG 23(5).