In This Issue:

- The Top 10 New York Tax Highlights of 2014

- Tribunal Affirms That a Charter Yacht Is Not Exempt from Use Tax as a Commercial Vessel

- Court of Appeals Holds City Transfer Tax Does Not Apply to “Reconstitution” of Housing Cooperative

- ALJ Denies Motion to Reopen the Record

- State Tax Department Outlines Policy on Transactions Using Virtual Currency

- Insights in Brief

- Excerpt from The Top 10 New York Tax Highlights of 2014:

2014 turned out to be a very eventful year in New York taxation. As we enter the New Year, here is our list of the Top 10 New York tax highlights of 2014.

1. Corporate Tax Reform legislation enacted. In what is surely the most significant New York development of 2014, on March 31, 2014 comprehensive corporate tax reform legislation was enacted and signed into law, effective for tax years beginning after 2014. Part A, Ch. 59, N.Y. Laws of 2014. Sweeping in scope, the new law undoubtedly represents the broadest revision to Article 9-A since its enactment in 1944. The legislation not only substantially overhauled Article 9-A — such as by adopting economic nexus, unitary water’s edge combination, market-based sourcing, and a 0% income tax rate for qualified New York manufacturers, and by eliminating the longstanding subsidiary income exclusion — it also merged the 30-yearold bank tax (Article 32) into Article 9-A. The corporate tax reform legislation was the culmination of a more than five-year initiative by the New York State Department of Taxation and Finance, and was carried out with the active participation of various industry groups. While the New York City general corporation tax was not amended, reportedly the City will attempt to enact similar legislation in 2015.