In Matter of NetVoyage Corp. aka NetDocuments.com, the New York State Tax Appeals Tribunal considered whether the company’s cloud-based document management platform constituted taxable prewritten computer software or a nontaxable document storage service. Following an audit of the company’s sales from June 2017 through November 2019, the Division of Taxation assessed additional sales tax
NY Tax Talk: Evaluating the sales tax vendor relief program
New York’s new sales tax vendor re-registration program includes a potentially valuable penalty and interest discount program for eligible vendors. However, qualifying for the program may be more complicated than it first appears, particularly for taxpayers with unresolved controversies or liabilities that are not yet fixed and final.
In this installment of NY Tax Talk
Paychex v. New York: Procedure before substance
In this episode of the SALT Shaker Podcast, hosts and Partners Jeremy Gove and Chelsea Marmor discuss the New York Appellate Division’s recent decision in Paychex v. Department of Taxation and Finance. Although the underlying dispute concerns whether certain reimbursement receipts should be included in New York’s business apportionment factor, neither the trial court
New York’s budget: What didn’t happen says as much as what did
The long-awaited New York State budget has arrived, and while it may not have produced major headline-grabbing tax increases, there’s plenty beneath the surface worth unpacking.
In this episode of the SALT Shaker Podcast, Partners Jeremy Gove and Chelsea Marmor are joined by Ken Pokalsky, Vice President of Government Affairs at The Business Council
Governor Hochul signs New York FY 2027 Budget into law
New York State’s long-awaited budget was signed into law by Governor Kathy Hochul on May 28, 2026.
The enacted budget retains most, but not all, of the tax reforms from the Governor’s January budget proposal discussed in our prior post.
Notably, New York State and New York City have decoupled from certain Internal Revenue
C is for cookie, that’s good enough for New York: P.L. 86-272 regs on Internet-based activities upheld
The New York Appellate Division unanimously affirmed a lower court order holding that New York’s regulation 20 NYCRR 1-2.10 – which addresses the application of P.L. 86-272 to Internet-based business activities – is not preempted by the federal statute. The American Catalog Mailers Association, a trade group representing merchants who sell goods through catalogs, telephone
New York’s extension of the primary function test leaves taxpayers buzzing
Bundled and mixed transactions continue to play an ever‑increasing role in New York sales tax determinations, particularly where nontaxable services are sold with software or other taxable property for one nonitemized price.
In this installment of “A Pinch of SALT,” published by Tax Notes State, Eversheds Sutherland attorneys Jeremy Gove and Periklis Fokaidis examine
NY Tax Talk: Calculating tiered partnership income
Questions around federal conformity and the scope of administrative agency deference continue to shape New York City tax disputes.
In this installment of NY Tax Talk, a quarterly column in Law360 focused on recent developments in New York tax law, Eversheds Sutherland attorneys Liz Cha, Diane Beleckas, and Madison Ball analyze a recent determination of
Services or software license? NY Appellate Division determines transactions are taxable sales of software
The New York Supreme Court, Appellate Division, affirmed a decision of the Tax Appeals Tribunal, which determined that a company’s charges for a proprietary technological platform, referred to as a “vendor management system” (VMS), constituted licenses to use prewritten computer software that were subject to sales tax. The company matched clients with suppliers of contingent
New York appellate court grants refunds for vehicle lease adjustments
The taxpayer, a fleet management company that leases fleets of commercial vehicles to businesses, used leases containing a terminal rental adjustment clause (TRAC). Under these leases, the lessee paid estimated monthly rent based on the projected residual book value of the vehicle at lease termination. When the lease ended, the estimated rent was retrospectively adjusted