United States vs New Zealand taxes

New Zealand is often sold as “no CGT, no estate tax.” Both statements are directionally true and incomplete. The United States is sold as “37% and 40% estate tax.” That is also incomplete once states and holding periods enter.

Resident New Zealand individuals are taxed on worldwide income at 10.5% to 39% for income from 1 April 2025. Employees usually also pay the ACC earners' levy through PAYE, 1.75% for 2026/27 on earnings up to NZD 156,641. That personal stack is close to, and then slightly above, 37% U.S. federal ordinary tax before a state income tax. New migrants and returning residents may get a transitional-resident exemption on much overseas investment income for about four years, which is a genuine inbound relief the United States does not copy for its own citizens.

The CGT slogan needs the property footnote. There is no broad standalone capital-gains tax on every share or fund sale. Gains are still income when the asset was acquired with an intention to resell, held on revenue account, or traded as a business. For residential land sold on or after 1 July 2024, the bright-line test generally taxes a sale within two years of the start date, subject to the main-home exclusion and other reliefs. A U.S. person used to 0% / 15% / 20% long-term federal rates can therefore face New Zealand ordinary rates of up to 39% on a quick house sale and 0% on a long-held listed portfolio that is not on revenue account. FIF rules can then tax many foreign shares and funds each year without a disposal, which is closer to a deemed-income regime than to U.S. realisation CGT.

Company tax is a U.S. win on the headline: 21% federal versus 28% for most New Zealand companies. Imputation credits can carry that 28% through to resident shareholders, which is a different distribution design from U.S. qualified dividends at 0% to 20% federally. GST is 15%. There is no general New Zealand net wealth tax and no inheritance tax.

Death is where U.S. persons should slow down. New Zealand will not charge estate duty. The United States still can, at up to 40%, for U.S. citizens and many U.S. domiciliaries, including on worldwide assets. Moving to Wellington does not by itself empty a U.S. taxable estate. Worldwide U.S. income tax also continues for citizens.

Model salary plus ACC against federal plus state, 28% against 21%, bright-line and FIF against U.S. CGT, and New Zealand's clean succession against a U.S. estate-tax file that may never close.