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The New York State Tax Appeals Tribunal affirmed an Administrative Law Judge determination that two taxpayers remained New York residents because the taxpayers did not establish that they had changed their domicile to Florida during the relevant tax years. Because the taxpayers spent “more than 30 but less than 184 days in New York,” the

While state and local governments have ended or relaxed mandatory work-from-home orders and are trying to bring back the in-person workforce, some employees remain hesitant to return to in-office work for numerous reasons. This trend may result in unanticipated tax obligations for employers and employees because many of the pandemic-related hold-harmless protections from withholding and

State taxation of a nonresident employee’s equity award, such as nonqualified stock options (NQSOs) or restricted stock units (RSUs), has long been a thorn in the side of many tax practitioners, payroll departments, and – of course – employees. In Appeal of Prince, California’s Office of Tax Appeals (OTA) recently addressed the state’s taxation

The New York State Supreme Court, Appellate Division, affirmed a New York City Tax Appeals Tribunal decision regarding the proper method for calculating a corporation’s receipts factor for General Corporation Tax purposes.  The corporation offered a subscription-based service that allowed its clients access to experts and consultants in a broad variety of disciplines, and access

The California Court of Appeal held that a county’s failure to comply with statutory notice requirements did not render an assessment a “legal nullity” that would excuse the taxpayer from the requirement to exhaust administrative remedies.

For property tax purposes, California requires a “Notice of Proposed Escape Assessment” (which levies a retroactive assessment to recapture

The Illinois Department of Revenue issued a private letter ruling determining that for purposes of the Retailers’ Occupation Tax (ROT) and the Services Occupation Tax (SOT), a taxpayer that procured marketing materials on behalf of its clients properly sourced these sales to the location of the product manager, the employee responsible for procuring the materials.