Residency Test

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New judgment on tax treaty between Germany and the US

Hybrid US S-Corporation eligible for participation exemption. Refund practice of taxes withheld remains to be seen. In a recent judgment (file no. I R 48/12), the German Federal Fiscal Court has commented on Art. 1...more

Gaied v. New York: The State's High Court Weighs In On Statutory Residence Rules

The concept of residency is usually the starting point for all state income tax considerations. And while almost every state imposes, at various rates, a personal income tax, in general the states use a similar sets of...more

New York's Highest Court Clarifies Taxpayer Criteria for Maintaining a Permanent Place of Abode

In a recent unanimous decision, the New York Court of Appeals determined that a taxpayer domiciled in New Jersey was not a New York resident because he did not maintain a permanent place of abode in the state. The Court...more

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