State Domicile and Residency

The New York Tax Appeals Tribunal recently held that a vacation home constitutes a “permanent place of abode” to make taxpayers statutory residents for New York income tax purposes.

The taxpayers, a married couple, were domiciled in New Jersey. The husband was a hedge fund manager who primarily worked out of his New York City

On August 13, 2020, the Utah Supreme Court agreed to hear a married couple’s direct appeal from a State Tax Commission decision holding that the couple was domiciled in Utah during the 2012 tax year under Utah’s “presumptive domicile” statute. Specifically, the case involves Utah Code Ann. § 59-10-136(2), which provides a rebuttable presumption

Calling all trivia fans! Don’t miss out on a chance to show off your SALT knowledge!

We will award prizes for the smartest (and fastest) participants.

This week’s question: Which state’s tax tribunal recently considered a domicile and residency case involving an eye doctor who moved to the Middle East after a divorce?

E-mail your

On December 2, 2020, a three-judge panel of California’s Office of Tax Appeals (“OTA”) issued a non-precedential decision ruling that a husband and wife remained domiciled in and residents of California for the 2013 tax year despite the husband leaving the state for an alleged “permanent” job in Alaska that lasted from April to July

On December 21, 2020, a three-judge panel of California’s Office of Tax Appeals (“OTA”) ruled in a non-precedential opinion that an ophthalmologist successfully abandoned his California domicile and became a California nonresident from May 25, 2013 through December 31, 2013 after moving to Saudi Arabia. For a brief overview of the various legal concepts involved

How do you change your state of domicile? What makes you a resident of a particular state? While these questions appear simple on the surface, the answers are complex and can vary depending on the state. That’s why Eversheds Sutherland’s SALT team has honed our knowledge and expertise on these issues to provide answers. Our

A New York City Administrative Law Judge held that a New Jersey S corporation (“Taxpayer”) was subject to New York City general corporation tax (“GCT”) on gain from the sale of a minority limited partner interest in a limited partnership that leased and managed New York City real estate. The Taxpayer argued that the gain

California uses market-based sourcing to apportion sales of other than tangible personal property to the state. Under the governing statute, sales of services are sourced to California to the extent the purchaser of the service receives the benefit in the state.1 Sales of intangible personal property are sourced to California to the extent the