The New York State Tax Appeals Tribunal upheld an income tax assessment and disallowed taxpayers’ claim of resident tax credits (RTCs) to the extent such RTCs were claimed for taxes paid to Connecticut on the taxpayers’ carried interest income. The taxpayers, both of whom were residents of New York, were employed by an affiliate of

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

On July 1, 2022, the New York State Department of Taxation and Finance issued the third set of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after January 1, 2015. The third set of draft regulations relate to apportionment, and contain revisions to the

In this episode of the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove teams up with Associate Cyavash Ahmadi to discuss the complexities of combined reporting, specifically comparing and contrasting the combined reporting regimes in New York and California. They discuss several of the nuances of both states’ systems and even debate what “Joyce v.

On April 29, 2022, the New York State Department of Taxation and Finance issued two sets of “final draft” regulations relating to the corporation franchise tax reform that took effect for tax years beginning on or after January 1, 2015. Since the sweeping corporate tax reform was enacted, the Department has published a series of

On April 12, 2022, the Appellate Division, First Department dismissed a taxpayer’s appeal from the New York City Tax Appeals Tribunal, and held that the Tribunal’s decision to uphold a tax assessment on an out-of-state entity’s gain from the sale of a partnership interest was “rational.”[1]

The taxpayer was an investment vehicle that formed