As most readers know, New York’s highest court recently issued a groundbreaking decision on the state’s residency rules — one of the first times that court has addressed this important New York tax issue. Gaied v. New York State Tax Appeals Tribunal, No. 26 (N.Y. 2014), has left practitioners and commentators buzzing over the ramifications for New York residency audits. Many think it is a big deal and that it will have a huge effect on future cases. Others have had more tempered reactions, viewing the case as a great win for John Gaied, but not one that will affect many others, given the unique facts in the case.
As the lawyers who litigated Gaied, we thought it was time to weigh in. And as one might expect, we’re in the ‘‘big deal’’ camp. When New York’s highest court makes a new pronouncement on income tax residency — an issue typically confined to administrative appeals — practitioners, taxpayers, and the New York State Department of Taxation and Finance have to take notice.
Originally Published in State Tax Notes - May 19, 2014.
Please see full Publication below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.