Our firm's State & Local Tax (SALT) Practice offers exceptional experience in all New York State, New York City, and multistate tax issues to our clients. The group’s New York State tax attorneys are also well-versed in multistate, international, and cross-border tax matters. From planning and compliance to litigation and damage control, our SALT Practice attorneys provide legal solutions specifically tailored to meet our clients’ requirements.
Hodgson Russ LLP has been awarded prestigious "Best Law Firm" rankings by Best Lawyers/U.S. News & World Report in the categories of National Tier 2, Tax Law and Litigation and Controversy – Tax, Metropolitan Tier 1, Tax Law, and Metropolitan Tier 2, Litigation and Controversy – Tax.
Our SALT Practice is also recognized by Chambers USA: America's Leading Lawyers for Business.
Leading the Way in State And Local Tax
Our SALT attorneys are leaders in tax law and tax litigation. Paul R. Comeau, the founder of the Hodgson Russ State and Local Tax Practice, handled some of the first residency audit cases in New York State in the late 1980's, and authored New York State Bar Association reports and articles that were subsequently reflected in detailed audit guidelines which continue to serve as a model for other states.
Timothy P. Noonan, the practice’s chief litigator, won a landmark residency case in New York’s highest court. Gaied v. New York State Tax Appeals Tribunal, No. 26 (N.Y. 2014), issued a groundbreaking decision on the state's residency rules, one of the first times the court addressed this important New York tax issue.
Hodgson Russ is also the first firm to use the provisions of the Civil Practice Law and Rules statute to obtain legal fees against the Tax Department in a litigated tax case.
Full Team Experience and Approach
While other firms of similar size may have one attorney who occasionally handles state and local tax matters, the Hodgson Russ SALT Practice has many New York corporate tax attorneys – with more than 20 attorneys. In addition to the attorney team members, our SALT Practice includes Paralegals, Audit Managers, and Senior Audit Managers, several of whom are former New York State tax auditors.
Areas of Concentration
Residency Planning
The SALT practice’s experience on residency planning is unparalleled. Thousands of taxpayers departing for sunnier tax climates have contacted the practice’s attorneys for advice on how to accomplish an effective change in tax residency even though they intend to maintain significant ties to the state they are leaving. While most of these calls come from individuals planning to leave New York City and/or New York State, the practice also receives inquiries from individuals seeking to depart other jurisdictions including, among others, California, Connecticut, Massachusetts, and New Jersey.
The SALT practice’s advice includes both how to carry out a move in a manner that should be respected on audit and how to structure business activities to reduce income sourced to the taxpayer’s state of former residency. We have provided counsel to high-net-worth individuals intending to move into high tax jurisdictions to structure their affairs in such a way as to minimize the impact of the higher tax rates. The practice’s lawyers are particularly experienced in some of the lesser-known legal traps and opportunities including accrual rules, convenience rules, and deferred compensation.
Transactional Planning and Due Diligence
Latent state and local tax issues have increased in frequency and importance as a result of the recent relaxation of nexus rules by the Supreme Court, and an increase of enforcement activity by the states against non-filers. As a consequence, the SALT practice lawyers are being called upon more often to identify and address state and local tax issues in acquisitive transactions. Our services include due diligence reviews of the past state and local tax compliance of target businesses, and when a problem is identified, offering solutions including, among others, increased escrows, indemnifications, and voluntary disclosure agreements to manage the possible impacts.
Tax Controversy Representation
The SALT practice lawyers have experience at all levels of tax controversy practice in New York State and City and experience in other jurisdictions. The practice’s lawyers appear on behalf of clients in audits, conciliation conferences, administrative hearings, administrative appeals, and civil court appeals. Sometimes the obvious approach is not the best approach, and the SALT lawyers are aware of the different procedural rules in the different courts and how the differences may be leveraged to the benefit of our clients.
The practice is acutely aware of the increasing cost of tax litigation and strives to keep clients aware of changes to the cost/benefit analysis as their cases work through the different tax controversy stages. Where appropriate, the practice will utilize the services of forensic accountants and expert witnesses. And our SALT lawyers are sometimes called-upon to appear as expert witnesses in cases in which the practice is not representing a client. Our lawyers also write and submit amicus (friend of the court) briefs in cases of particular significance.
Multistate Tax Issues
Hodgson Russ’s income and sales tax lawyers help many businesses that are in another state deal with the widely varying tax laws and regulations that affect them. We also help clients create a plan of action for managing multistate tax compliance using our proprietary Matrix planning tool to help clients quantify their exposure through a state-by-state analysis of audit risk and liability concern.
Knowledge Is Power
We wrote the book. Any lawyer can read the books necessary to become proficient in an area of law, but the Hodgson Russ SALT Practice attorneys write those books. These publications were written by our attorneys:
- New York State Sales And Use Tax Answer Book, CCH (2013 Edition)
- Contesting New York State Tax Assessments, 4th Edition
- Guidebook to New York Taxes, 2019 Edition
- New York Residency And Audit Allocation Handbook, CCH (2018 Edition)
- What to Expect in a Sales and Use Tax Audit
- What to Expect in a Residency Audit
To learn more about how to obtain these handbooks, please click here.
Other Publications of Interest
New York Tax Treatment of S Corporations and Their Shareholders, discontinued by the New York State Department of Taxation and Finance
'State Tax Talks with Joe Tantillo" Podcast
The Hodgson Russ State & Local Tax Practice is ready to un-complicate some of New York State’s most complicated tax laws and requirements for you. Subscribe to our podcasts for instant access to the latest episodes of “State Tax Talks with Joe Tantillo.”
Practice Leader
- Partner
Experience
- Counsel in Multistate Residency Litigation
- Gas Import Tax Declared Unconstitutional
- New York and Florida Residency Planning
- New York State 548-Day Rule Tax Planning
- Tax Counsel in Significant State Residency Case John Gaied v. New York State Tax Appeals Tribunal
- Victory in Multi-Million Dollar NY Tax Audit of Exempt Resident Trust
People
- Open Weaver BanksPartner
- Brandon J. BourgAssociate
- Rhonda BrinkmanSenior Audit Manager
- Mario T. CaitoAssociate
- Peter R. CalleriAssociate
- Paul R. ComeauPartner
- William J. ComiskeyPartner
- Brittany A. CosoAudit Manager
- Ariele R. DoolittlePartner
- Christopher L. DoylePartner
- Catherine B. EberlPartner
- Joseph N. EndresPartner
- Debra Silverman HermanPartner
- Daniel P. KellyPartner
- Mark S. KleinPartner
- Joshua K. LawrencePartner
- Diana MathisSenior Audit Manager
- Joshua MrukParalegal
- Timothy P. NoonanPartner
- Elizabeth PascalPartner
- Zoe H. PeppasAssociate
- K. Craig ReillyPartner
- Emma M. SavinoSenior Associate
- Joseph F. TantilloAssociate
- Michael Van WagnenSenior Audit Manager
- Andrew W. WrightPartner
News & Insights
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There are an order and two determinations this week for your thoughtful consideration. The order refers to 36 separately numbered allegations of error by the Division. And, because I am of a certain age and it is Thanksgiving season, this triggered a memory of “Alice’s Restaurant Massacree” by Arlo Guthrie. The song was notable for its 1960s anti-establishment narrative and wry humor. It also took up one whole side of an album. For the benefit of you kids out there, albums were round vinyl media for delivering permanently embedded audio content. Back in the day, most album sides had between five to seven songs making up roughly 22 minutes of audio. In the 1970s and 1980s, we dinosaurs would re-record both sides of an album onto the single side of a 90-minute cassette tape so we could have two albums’ worth of music on one tape to play in our cars since there was no easy way to play a vinyl album in a moving vehicle.
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TiNY has been off the air for the last few weeks while waiting for the DTA to provide enough content for us to prepare a Report with critical mass. Cases have been dribbling out recently, and over the last three weeks, there is just one Tribunal decision and one ALJ determination on which to report. We had hoped for more this week and were disappointed.
Still, the Decision and Determination were not process cases (i.e., neither case involved timeliness or other jurisdictional issues). So, at least there is some substance there.
The next TiNY Report will be post-election. Thank goodness. Talking heads of all stripes are launching their partisan grenades at a frequency that is impossible to ignore. Your editor yearns for simpler times when 95% of the news he needed came from the Weather Channel, ESPN, Tax Notes, Weekend Update, and the DTA website.
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There were no decisions or determinations posted in the last two weeks. There was, however, an order posted each week.
And in other news: Prior to September 27, only lawyers, CPAs, enrolled agents, select employees and officers of businesses, and certain others (those with the Division of Tax Appeals’ permission) could represent taxpayers in matters before the DTA. As the result of a recent law change, taxpayers may now elect to be represented by their niece, babysitter, the kid who cuts their lawn, or anyone else who has achieved the wizened age of eighteen. Heaven help the first pimple-popping Rep that asks Judge Law to adjourn a hearing because it conflicts with their prom.
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Welcome back, constant reader. There’s no snappy introduction this week since I have a lot of client work sitting on my desk. Instead, I have the following confessions:
I am a fan of the Buffalo Bills, and I am impressed by their control of the first three games. But … I am a fan of the Buffalo Bills, so I recognize that the records of the Bills’ first three opponents are a combined 2 wins and 7 losses. I am a fan of the Buffalo Bills, and I am optimistic, but only cautiously optimistic. I am a fan of the Buffalo Bills, so I believe that maybe this one time, Lucy will not pull the football off of the tee before I kick it.
There’s a bunch of jurisdictional boredom in last week’s cases. And there are a few nuggets: For instance, I admire the Tribunal for imposing, on its own motion, a frivolous petition penalty in one of the Decisions. And ALJ Chu-Fong dropped some breadcrumbs that might lead some COVID-era non-resident taxpayer-employees away from New York’s dark and ominous convenience of the employer forest and out into the sunshiny fields of bona fide business necessity. And with that overly long and tortured metaphor, I bid you adieu.
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It seems like the DTA has been doing a bit of end-of-the-summer cleaning as we careen back into school-days mode. Most of the determinations posted over the last two weeks were summary dismissals of cases in which the petitions were deficient for a number of reasons. These determinations are very short, and our TiNY summaries are similarly brief. But there are a couple of cases that merited a more thorough analysis. So, enjoy!
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The Kids are back to school and the DTA is back to issuing determinations and decisions that are mostly timies and dismissals for lack of jurisdiction. Matter of Bryant is of some interest in that the credit denial in that case was based on a lack of information from an agency that was not the NYS Tax Department. The taxpayer’s inability to get information from the other state agency was the reason he could not satisfy his burden of proving entitlement to the credit. It sounds like Petitioner made many attempts to get the information but was stymied. Did the information exist? Was the inability to retrieve the information due to some failure on the part of the other administrative agency? We’ll probably never know.
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There were three determinations to report on this week, and a majority of them are not Timies! The two substantive cases address how to properly source income from a trade, business, or profession carried on, or previously carried on, in New York under Tax Law § 631. And in both cases, the Judges found that such sourcing needed to follow the path set forth in applicable regulations as required by the statute.
I didn’t watch any of the Olympics other than the part of the closing ceremonies when they cut from Paris to LA. But I heard that break dancing was an Olympic event in Paris for the first time – but it’s already been axed for the next Summer Games. Wow. Since the Summer Olympics are going to LA in 2028, maybe they can have an Olympic event like the contest at the end of “Eight Mile” when B-Rabbit resorts to a self-deprecating rap to dispatch Papa Doc. I liked that, so I’d probably watch something like that again. And like in Eight Mile, shouldn’t the audience (maybe the TV audience to avoid host-country bias) participate in the judging of certain Olympic events?
The IOC knows where to find me if it needs more suggestions.
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The mental conversation I just conducted with myself:
“What should I write today about this TiNY Report being late again?”
“How about the truth? You have been diverting your non-billable attentions to the summer because ‘summertime is running out’ and ‘supplies are limited.’”
“No one cares about your personal life. How about ‘no excuses” since you have no excuses.”
“The Alice in Chains song ‘No Excuses?’ That’s a good one. For some reason that song reminds me of the Blues Traveler tune ‘The Mountains Win Again.’"
“Wow. 90s much?”
“Shut up.”
“No, you shut up.”
(nothingness)
We present a bunch of pent-up case summaries today, only a few of which have a worthwhile tale to tell. For my money (ed.: there’s actually no money involved) I recommend Saslaw, in which a pro se petitioner won a difficult responsible officer case; Rockaway Realty Associates, involving a local mortgage recording tax refund claim (a unicorn of a case if ever there was); and Lynch, discussing the limitation in the “548-day rule” prohibiting spouses from remaining in New York during the relevant period.
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Over the past few years, we’ve seen a major expansion of enforcement efforts by the New York City Department of Finance, particularly with respect to the City’s unique Unincorporated Business Tax (the “UBT”). In these audits, DOF has been taking increasingly aggressive positions around the application of various statutory provisions.
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Over the past decade, New York and other states have employed some version of a “False Claims Act” (FCA) to enforce violations of the tax law, and occasionally these cases wade into residency and personal income tax waters. One of the tax jurisdictions is the District of Columbia, and recently they scored a big win in a FCA case.
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Your TiNY editor-in-chief took some time away over the long weekend and that led to the late posting of this week’s TiNY Report. The delay gave us some time to reflect on Hodgson Russ’s slick replacement website. When we commented favorably on the new site to our marketing personnel, we were told this interesting tidbit: When the old site was converted to the new site, spell check was automatically run. And 99% of the flagged words were found in the TiNY blog. Further investigation disclosed that sometimes the authors of TiNY make up words (The shock! The horror!). And I was reminded (not for the first time) that Hodgson Russ blogs are informational and need to accurately recount legal developments without the use of humor, sarcasm, or hyperbole. Hodgson Russ blogs are not to entertain, they are to inform. They are not a linguistic playground on which the authors might vent pent-up frustrations brought about by years of straight-jacketed legal writing. And they should never besmirch the language of Shakespeare by creating words.
Right. If you feel that way, perhaps you should read TiNY’s disclaimer.
This week we’re covering four determinations for your consideration. Two of them—Maragh and Somers—are worth a listen-to. The other two are songs that you liked a little when they first came out but now detest because they have been overplayed on your favorite radio station.
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This year the Hodgson Russ annual Labor & Employment Conference will be presented as a three part webinar series. Join our attorneys as they provide insight into some of the most critical issues of 2020, including the latest updates in light of COVID-19.
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Timothy P. Noonan explains how New York State sales tax are applied to discounted items.
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New York Sales and Use Tax Answer Book, written primarily for tax practitioners, is a comprehensive resource that covers the full range of statutes, regulations, and legal rulings that govern New York State’s sales and use tax.
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BUFFALO, N.Y. — Hodgson Russ LLP is pleased to announce that the following attorneys have been elected to the firm’s partnership: Timothy P. Noonan, David G. Reed, Jeffrey C. Stravino, and Brian K. Duffey.
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BUFFALO, N.Y. — Mark S. Klein, a partner in Hodgson Russ LLP’s State & Local Tax and Tax Dispute Resolution Practice Groups, is the contributing editor of the <em>2007 Guidebook to New York Taxes</em>.
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The Burton Award is presented in association with the Law Library of Congress. It honors 20 winners selected from nominations from the top 500 law firms in the United States and 10 winners from leading U.S. law schools.
Podcasts
- Common Tax Residency Topics (Part 2)
Joe, Mark Klein, and Andrew Wright continue their discussion about common tax residency errors, and the panel delves into topics that frequently create unnecessary difficulty in New York State audits. Everything from “country club advice” to errors in the tax return, this episode is a must listen for anyone considering making a move out of state.
- Common Tax Residency Traps (Part 1)
Joe is joined by Mark Klein and Andrew Wright to discuss some of the most common errors in the world of tax residency. The panel discussed misconceptions related to changing your residency, such as misunderstanding surrounding the six months and a day test and failing to move near and dear items to your new home. These common mistakes can derail and otherwise carefully planned move for taxpayers who are not careful.
- California Tax Residency Rules (Part 2): Temporary/Transitory Purpose & Closest Connections
Joe and Dan continue their discussion on California’s tax residency rules, and they delve into the complexity and ambiguity of California’s temporary/transitory purpose test. They highlight the unique rules associated with the test, and they discuss how California leans on the objective factors in its “closest connections test” when the temporary/transitory analysis doesn’t result in a firm domicile determination.
- California Tax Residency Rules (Part 1): Domicile
In this episode of State Tax Talks, Joe brings in California tax professional and Hodgson Russ Partner, Daniel Kelly for a nuts and bolts overview of California’s rules on changing your residency for tax purposes. The two start at the top with a discussion on California’s law surrounding domicile as well as a few safe harbor provisions included in the California tax law. California, much like New York, utilizes a complex analysis for making a determination as to whether someone has successfully abandoned their California residency. Dan and Joe look to peel back the layers of the primary test for our listeners.
- Moving Abroad: Challenges & The 548-Day Rule
Changing your domicile can be a challenge. Changing your domicile to a foreign country is an even bigger challenge. Joe is joined by Tim Noonan and Diana Mathis for an in-depth discussion of the rules governing changes of residency out of New York to a foreign country. The panel also discusses the 548-Day Rule safe harbor within the New York tax law, which allows people to escape taxation as a resident if they spend enough time abroad and meet other requirements.
- Pass-Through Entity Tax 101 (Part 2): Income, Credits, and Add-backs
In part two of our pass-through entity tax discussion, Joe, Liz, and Chris discuss the nuts and bolts of calculating PTET income for partnerships and S-corporations. The panel also discusses the complexities surrounding the credit and the addback of taxes paid at the individual level in New York. The panel also dives into some of the nuances of the New York City pass-through entity tax as well as some frequently asked questions that arise in the world of PTET.
- Pass-Through Entity Tax 101 (Part 1): History, Purpose, & Making the Election
Joe is joined by Hodgson Russ partners Liz Pascal and Chris Doyle to discuss the nuts and bolts of the pass-through entity tax. The panel begins its discussion with an overview of what exactly a pass-through entity tax is, and how it’s tied to the Tax Cuts and Jobs Act of 2017. The panel also discusses some of the basics of making the PTET election, including who can make the election and when the deadline is in New York State.
- The Zelinsky Case – Tax Department Wins Round 1
The administrative law judge in the Zelinsky case issued a determination in favor of the tax department. Andrew Wright and Brandon Bourg join Joe Tantillo to discuss the analysis in the determination and break down what this means for the case moving forward. For now, the convenience rule remains good law, but will the analysis hold on appeal? Tune in to hear our thoughts.
- Stupid Sales Tax Rules
Have you ever really looked into some of the distinctions between what makes an item taxable or nontaxable in New York? Well, we have, and some of the rules are just plain outrageous. Joe is joined by Mark Klein, Joe Endres, and Josh Lawrence to discuss some of New York State’s silliest sales tax rules. You’ll be shocked at how the tiniest difference can result in a hefty sales tax bill. The panel shares stories about some of the niche sales tax issues that have come up on audit.
- New York State Brownfield Program (Part 2): Tax Credits
Joe continues his conversation with Hodgson Russ partners Michael Hecker and Joseph Endres, as the trio discusses the dynamic Brownfield Program. The conversation shifts to the sizeable tax credits available to developers looking to take advantage of the Brownfield Program. Joe Endres highlights how these credits are calculated, claimed, and what scrutiny the tax department may use when reviewing Brownfield credit claims.
- New York State Brownfield Program (Part 1): Cleanup & Compliance
Joe is joined by Hodgson Russ LLP partners Michael Hecker and Joseph Endres to discuss the ins and outs of New York State’s Brownfield Program. Federal and State Brownfield Cleanup Programs (BCPs) present unique opportunities for revival of contaminated properties in economically blighted communities and turning barriers to development into productive commercial or industrial sites. These programs also serve as one of the tools that may be used alongside a wide array of other economic development programs to leverage dollars and investment for various types of redevelopments, while providing essential protections against long-term risk. Brownfield projects require a step-by-step understanding of the process in order to ensure those undertaking the project receive the maximum benefits available. Mike shares his expertise on the regulatory and operational compliance required to undertake a Brownfield Project, and the steps to be completed long before the benefit of the Brownfield tax credit can be received.
- Allocation & Apportionment (Part 3): Business Income
In the final part of our allocation and apportionment series, Joe, Chris, and Andrew discuss the nuts and bolts of apportioning business income. The apportionment and allocation of business income often varies based on the type of business entity, which can create confusion for business owners. The panel tries to simplify this process by taking a look at New York’s rules for corporate and partnership apportionment.
- Allocation & Apportionment (Part 2): Wage Allocation
Joe, Chris, and Drew continue their series on allocation and apportionment. In this episode, the panel breaks down the nuts and bolts of nonresident wage allocation, and the impacts of telecommuting on the workday allocation fraction. The trio also discuss the difference between allocating salary and bonus income.
- SALT Minds: An Interview with Professor Edward Zelinsky
Joe is joined by esteemed legal scholar, Professor Edward Zelinsky of the Benjamin N. Cardozo School of Law, and Hodgson Russ colleagues Elizabeth Pascal and Timothy Noonan to discuss Professor Zelinsky’s ongoing legal battle against New York State’s Convenience of the Employer Rule. Professor Zelinsky shares stories about his original convenience rule court case and provides insight into how his legal theory evolved for his newest court case in opposition of the convenience rule.
- Allocation & Apportionment (Part 1): The Basics
Joe is joined by Hodgson Russ Attorneys Andrew Wright and Chris Doyle to begin his series on nonresident allocation and apportionment. The group dives into the very basics of the topic, and answers the all-important question of what distinguishes allocation from apportionment.
- Introduction to Sales Tax (Part 3): Audits
Our introduction to sales tax series comes to a close with an in depth discussion on the audit process. Have you ever wondered what happens in a New York State sales tax audit? Joe Tantillo and Joe Endres break down the ins and outs of the audit process. They discuss the rights of the taxpayer, audit procedure, and potential outcomes.
- Introduction To Sales Tax (Part 2): If I Sell It, Will They Tax?
The two Joes continue their sales tax discussion by venturing into the topic of taxability. They discuss the basics of the taxation of sales of tangible personal property versus sales of services. And Joe Endres poses some interesting hypotheticals about the applicability of the New York State sales tax.
- Tax Provisions of Interest in the Proposed 2023-2024 New York State Budget Bill
Joe sits down with SALT attorneys Chris Doyle and Mario Caito to discuss some highlights from the New York State Legislature’s proposed Revenue portions of the State’s 2023-24 Budget (Assembly Bill 3009/Senate Bill 4009)(the “Budget”). The group also highlights some of the proposed tax rate increases and wealth tax proposals that have been floated by state legislators.
- Introduction To Sales Tax (Part 1): Nexus
Joe is joined by sales tax expert and SALT attorney, Joe Endres, for the first part of our Introduction to Sales Tax Series. The pair discuss one of the most important issues in the world of sales tax: nexus. Often a threshold issue for companies trying to determine the taxability of their sales, nexus is the connection between a seller and a state that requires the seller to register then collect and remit sales tax in the state. Whether a seller has nexus with a given state can be a complicated matter even for the most experienced tax professionals. The two Joes break down the law of nexus and analyze the complexities of the law.
- Obus and the Future of Statutory Residency
A major win for taxpayers, the decision in Matter of Obus v. New York State Tax Appeals Tribunal is final! Joe is joined by guests Tim Noonan, Andrew Wright, and Emma Savino to discuss this landmark tax case, which will dramatically shift the rules for New York’s statutory residency test. We break down the cases that led up to this point, what actually happened in Obus, why the impact of the case is significant, and what the future may hold for legal interpretation of what constitutes a permanent place of abode in New York. A once purely mechanical test, the statutory residency test now looks to have a major subjective component as part of the analysis, as a result of the Obus decision. Joe and his guests also give their thoughts on whether the State will take action in response to this major change.
- Happy Minute 2 – The Convenience Rule Continued: Matter of Zelinsky
Joe and guests Chris and Dan continue their conversation about New York State’s Convenience of the Employer Rule. They focus their discussion on one of the most famous court cases to ever challenge the Convenience Rule, Matter of Zelinsky v. Tax Appeals Tribunal of the State of New York. They also discuss Professor Zelinsky’s renewed challenge to the Convenience Rule, the challenge’s chances of success, and the best arguments against upholding the rule as constitutional.
- Happy Minute 1—The Convenience Rule
Welcome to the first edition of the Happy Minute: a laid back, round-table style discussion of contemporary tax issues that pique our interest. Joe is joined by guests, Chris Doyle and Dan Kelly, to discuss the Convenience of the Employer Rule used by New York and a handful of other states to tax the wage income of remote employees. This is a nonresident allocation rule that can be confusing to many taxpayers, especially those working remotely for New York employers. Joe, Chris, and Dan talk about how the rule works, why it negatively impacts remote employees, and whether it is fair for states to use a convenience rule.
- Residency Audits- Part 2
In a continuation of their discussion on tax residency, Tim and Joe dive into the ins and outs of tax residency audits, including a high level discussion of audit procedure. The pair talk about what taxpayers can expect if they get an audit notice, and highlight some of the realities of a New York tax audit.
- Residency Audits- Part 1
In this episode, Joe sites down with Tim Noonan in the first part of our discussion on tax residency. Changing your tax residency is not as simple as spending six months and a day in a new state. Tim and Joe discuss the ins and outs of New York State’s tax residency tests, and share thoughts on what factors tend to trip up taxpayers looking to make a move out of state.
- A Brief History of State and Local Tax Part 2
In Episode Two of “State Tax Talks with Joe Tantillo,” Joe and the "Tax Titans", Paul Comeau and Mark Klein, continue their discussion of the development of SALT legal practice.
- A Brief History of State and Local Tax
In Episode One of “State Tax Talks with Joe Tantillo,” Joe provides an overview of the development of SALT legal practice, as told by experts, Paul Comeau and Mark Klein (or as we call them, the “Tax Titans”).
You won’t want to miss this!
- State Tax Talks TRAILER
You’ve probably heard the saying, “Knowledge is power.” When it comes to taxes in New York State, we couldn’t agree more!
Areas of Expertise
We proudly offer legal expertise in the following areas of New York tax law:
- Corporate Tax
- Domicile & Residency Law
- Litigating a New York State Tax Case
- Nonresident Allocation Rules
- Sales & Use Tax
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