Many Massachusetts residents have recently considered taking, or have undertaken, steps to relocate from Massachusetts to jurisdictions with lower or no state income taxes, especially in light of the recently enacted 2023...more
In the wake of the COVID-19 pandemic and increased remote work, multistate income tax and payroll tax withholding responsibilities have received heightened consideration nationwide. Employers keen on retaining and attracting...more
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
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
The term “resident” is defined differently for US federal income tax purposes and US federal estate and gift tax purposes. The mismatch in the US resident status under the two tax regimes often gives rise to problems. Thus,...more
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
As a result of the COVID-19 pandemic, many states and localities tried to continue taxing nonresident employees who stopped working from their employer’s location and began working from home in another jurisdiction. The...more
The Ohio Supreme Court upheld the right of Ohio municipalities to tax wages earned by employees working outside the municipality from home during the COVID-19 pandemic. Schaad v. Alder Slip Opinion No. 2024-Ohio-525 (Feb. 14,...more
On February 14, 2024, in Schaad v. Alder, the Supreme Court of Ohio upheld the constitutionality of a temporary Ohio law allowing municipalities where a principal place of business was located to collect income tax from...more
A New York nonresident taxpayer, Edward Zelinsky, recently filed a notice of exception to a Division of Tax Appeals’ (DTA) determination that he must allocate all his wages to New York under the so-called “convenience of the...more
Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more
New Jersey enacted Assembly Bill No. 4694 on July 21, 2023, adding a “convenience of the employer” rule in an effort to gain tax revenues from nonresidents assigned to a primary work location in New Jersey who work outside...more
The general rule of thumb for nonresidents has long been that nonresidents can only be taxed by a state on income earned in that state (i.e., source income). Seems simple enough, right? As every state tax professional knows,...more
On May 4, 2023, Indiana Governor Eric Holcomb signed legislation (Laws 2023, SB419) that, among other tax changes, included provisions to exempt from income tax nonresidents receiving compensation for employment duties...more
Moving to or purchasing real estate in the United States as a nonresident requires careful consideration of US federal income, estate and state and local tax laws. Inbound US federal tax planning involves analyzing these laws...more
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
According to a report issued by the National Association of Realtors a couple of days ago, last year saw a large outmigration of people from California and New York, while Florida and Texas experienced a comparably large...more
“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
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
The HSB Economic Development team published their June 2022 news update, highlighting the following topics: Big Changes to South Carolina Property Taxes and Incentives- The big political news in South Carolina this June...more
Many companies are shifting to remote or hybrid workplaces. Our legal and tax professionals are teaming together to highlight hot-button issues for your remote workforce. TAX PITFALLS •Employment •Income tax •Residency ...more
Last month, the Mexican federal government sent the proposed 2022 Economic Plan (the Proposal) to the Congress of the Union, which includes the 2022 Federal Budget, as well as the 2022 Revenue Law (Ley de Ingresos) and...more
The United States Supreme Court ("Supreme Court") denied New Hampshire’s bid to strike down as unconstitutional the Massachusetts regulation that governs personal income taxation for nonresidents who have been telecommuting...more
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days. This frequently happens in an understandable...more
The Supreme Court of Ohio upheld the City of Cleveland’s taxation of a nonresident’s income from stock options even though the income was recognized by the nonresident seven years after the nonresident had ceased working or...more