A recent New York City (“NYC”) determination limited the impact of the step transaction doctrine under the New York City real property transfer tax (“RPTT”). An Administrative Law Judge (“ALJ”) held that the collapsing of a...more
Although it has been more than 20 years since the enactment of customer-based sourcing for registered securities broker-dealers under the New York State corporate franchise tax, there have been few cases interpreting it....more
Two recent New York State decisions illustrate the importance of the “primary function” test for determining taxability under the New York State sales tax, in both cases involving the tax on information services. Applying...more
A recent decision involving the New York City unincorporated business tax addback for payments to partners is an important reminder that the addback may sometimes be applied even for payments that are not made to a partner of...more