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Drop & Swap Like-Kind Exchange Passes Muster in New York

New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more

New York Sales Tax: When a Responsible Person Acts Irresponsibly

Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more

Employer to Nonresident Employee: “You Cannot Work in New York”; New York to Employee: “We Will Tax You Anyway”

You are probably aware that many employers are discarding the fully flexible, remote work policies that were forced upon them – as “nonessential” businesses – during the COVID-19 pandemic[i] and which they retained as an...more

Abandoning N.Y. Domicile – Must the Business Owner Abandon Their N.Y. Business?

During the weeks leading up to the Presidential election, the media carried stories about wealthy supporters from each Party who had announced their intention to leave the country if the other Party’s candidate became...more

New York Tax Continues to Inconvenience Nonresidents Working Remotely

Last Friday, New York’s Governor Hochul delivered the following remarks at the annual meeting of the Business Council of New York State:“Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising...more

New York’s Tax Treatment of Compensatory Restricted Stock and Dividends in the Hands of a Nonresident Executive

As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more

New York Can Be Stingy Giving Credit – Resident Tax Credit, That Is

The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more

N.Y. Sales Tax – Responsible Person Liability

NY Needs the Revenue- A couple of weeks ago, the Tax Foundation released its latest “State Business Tax Climate Index,” which assesses a state’s tax system and compares it to that of other states. New York seems to be a...more

Pre-Consolidation Conversions in the Accounting World – Tax Considerations

Another Change- Last week BDO confirmed that it was going to convert from an entity organized as a limited liability partnership under state law to one organized as a corporation. With that, BDO became the latest in a...more

Some Observations On Recent Conversions of Partnerships to “C” Corporations

Decisions- It is often the case that the optimal form of legal entity through which a business should operate, at least for income tax purposes, will depend in part upon the stage of its life cycle in which the business...more

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground. In a sense, New...more

Will New York Increase Taxes On Investment Income?

Last Thursday, New York State Senator Gustavo Rivera, who represents the 33rd District (basically, the northwestern quadrant of The Bronx), proposed legislation that seeks to collect more taxes from the State’s high-income...more

Thinking About Leaving New York? Don’t Forget to Check Your Federal Tax Return

The Mid-Terms- With 50 seats in the Senate, the Dems still control that Chamber. A win in the Georgia runoff, however, may lessen the burden for Majority Leader Schumer by, perhaps, neutralizing the significance of a certain...more

NJ Publishes Guidance on Cannabis Sales & Use Tax and Social Equity Excise Fee

The New Jersey Division of Taxation recently provided guidance on registration and licensing requirements, Social Equity Excise Fees, and the Sales & Use tax applicable to companies operating in the cannabis industry. ...more

Push-Back On New York’s Mission to Tax Non-New Yorkers?

Last week, Governor Murphy of New Jersey staked out a position on New York City’s congestion pricing proposal, stating that it “can’t be ‘on the backs of New Jersey commuters.’” “Whether it’s how we’re taxed by our...more

When New York Taxpayers Move Overseas

Everyone has heard about the affluent, or even not-so-affluent, New Yorkers who have moved to Florida, or to another state, to escape New York’s tax regime, not to mention the cold. More recently, some of us are...more

Leaving New York? Can You Prove It?

“Summertime and the Living” Isn’t Easy- Summer in the New York Metro Area can be challenging. Some would say it sucks. It gets really hot. When it rains, it pours – no spritz here. The humidity is oppressive. Ironically, a...more

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more

Will New York Be Looking At Your Federal Tax Return? Probably

State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

The Deduction of Cannabis Business Expenses Following New York’s 2023 Budget

The 2023 Budget- Last week, the New York Legislature passed the State’s 2022-2023 Budget. The $220 billion Budget reflects an $8 billion increase over last year’s budget (a more than 3 percent jump). It is also $4 billion...more

The Liquidation of a Partner’s Interest Under NYC’s Unincorporated Business Tax

Taxes and Snowy Weather? How many of you awoke Saturday to find that the winter storm about which we had heard so much during the preceding days had lived up to its hype? What was your first thought? “Fudge,” right?...more

Revised Nonresident Audit Guidelines For New York Statutory Residence

Last Week- What a week it was. It began relatively well, with the Cowboys losing the NFC wild card game, albeit to a California team. It ended disturbingly, with the Arizona Democratic Party censuring Senator Sinema...more

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