Corporate Taxes, Administrative Law Judge (ALJ), Tax Appeals

4 Key Takeaways | Market Based Sourcing and Discretionary Adjustments

Kilpatrick on 5/1/2025

On April 24th, Kilpatrick tax partner Jeff Reed presented during a New York City Bar SALT Committee meeting. Jeff discussed the recent Jefferies Group LLC & Subsidiaries New York Tax Appeals Tribunal decision....more

You Can’t Touch This: Sale Of Partnership Interest By Nonresident Corporate Partner Deemed Subject To NYC Tax Despite Lack Of...

Akerman LLP - SALT Insights on 4/8/2019

The decision by the New York City Tax Appeals Tribunal in Goldman Sachs Petershill Fund Offshore Holdings Corp (“Petershill Fund“), unfortunately, does not involve parachute pants or any reference to the “Running Man” dance....more

MoFo New York Tax Insights - Volume 7, Issue 7

Morrison & Foerster LLP on 7/7/2016

ALJ holds NYS Real Estate Transfer Tax Cannot Be Imposed on Sale of 45% Membership Interest in LLC - In an issue of first impression under the New York State real estate transfer tax, a New York State Administrative Law...more

MoFo New York Tax Insights - Volume 7, Issue 5

Morrison & Foerster LLP on 5/5/2016

Retroactive Application Of 2010 Statutory Amendment Permitted By Tribunal - Reversing the decision of an Administrative Law Judge, the New York State Tax Appeals Tribunal has upheld the constitutionality of retroactively...more

MoFo New York Tax Insights - Volume 7, Issue 4

Morrison & Foerster LLP on 4/5/2016

ALJ holds that Insurance Payments to Captive Insurance Company Are not Deductible - In Matter of Stewart’s Shops Corp., DTA No. 825745 (N.Y.S. Div. of Tax App., Mar. 10, 2016), a New York State Administrative Law Judge...more

ALJ: New York NOL Deduction Does Not Apply When Tax Is Not Paid on Income Base

McDermott Will & Emery on 2/18/2015

A New York State Division of Tax Appeals administrative law judge (ALJ) recently determined that a banking corporation was not required to hypothetically use a net operating loss (NOL) deduction to decrease its entire net...more