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Income Taxes › Administrative Law Judge (ALJ)

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Blank Rome LLP

New York City ALJ Rules That Deductions Allowable for Federal Income Tax Purposes Are Also Allowable under the UBT

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In a recent case, a New York City Administrative Law Judge (“ALJ”) determined that the City’s unincorporated business tax (“UBT”) did not impose a second, discrete requirement that a deduction need be directly connected with...more

Rivkin Radler LLP

An Inveterate Golfer At the IRS

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As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022...more

Pillsbury - SeeSalt Blog

New York State Tax Appeals Tribunal Rejects Sourcing of Partnership Income to that Partnership’s Operating Location

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The New York State Tax Appeals Tribunal (Tribunal) held that a taxpayer’s distributive share income from a partnership was intangible income properly sourced to the taxpayer’s residence and not to the location of the...more

Blank Rome LLP

New York State Tax Appeals Tribunal Denies Resident Credit for Tax Paid to Connecticut on Carried Interest

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The New York State Tax Appeals Tribunal ("Tribunal") held that a New York resident was not entitled to a resident tax credit for tax she paid to Connecticut on her carried interest. Matter of Greenberg, DTA No. 829737 (N.Y.S....more

Sheppard Mullin Richter & Hampton LLP

FTC Judge Orders Tax Filing Software Company to Stop Advertising Products as “Free”

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On September 8, the FTC’s Chief Administrative Law Judge (“ALJ”) issued an initial decision finding that a company providing tax filing software services engaged in deceptive advertising practices in violation of Section 5 of...more

Rivkin Radler LLP

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

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Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

Freeman Law

Texas Tax Roundup | January 2023

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Hiya, folks and welcome back to a whole new edition (in a whole new year) of the Texas Tax Roundup! January started the year off with a blast! Let’s see what happened!   Sales and Use Tax  Governmental Exemption...more

Freeman Law

Texas Tax Roundup | December 2022: Sweepstakes, Medical Records, and More!

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December was a bit of a slow month on the Texas tax front. Hopefully everyone was out of their respective offices and enjoying the holidays/resting up for the upcoming legislative session. Still, we got an interesting opinion...more

Freeman Law

Texas Tax Roundup | November 2022: What’s a Franchise Tax?

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Hey everybody! Welcome back to another for another edition of Texas Tax Roundup! Hope y’all had a happy Thanksgiving! We got some franchise tax apportionment, some sales and use tax in the oil and gas industry, and some...more

Freeman Law

Texas Tax Roundup | August 2022

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Howdy folks, and welcome back to another action-packed edition of the Texas Tax Roundup! Let’s see what shocking developments in the realm of Texas tax that the month of August had in store!...more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

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Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Rivkin Radler LLP

Leaving New York? Can You Prove It?

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“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

Rivkin Radler LLP

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

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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

Freeman Law

Texas Tax Roundup | February 2022 (RECOVERED!)

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Howdy y’all!  Has it been a month already?  We’ve got another action-packed month of Comptroller-related news.  Here we go! Court Cases Courts of Appeals Hegar v. Black, Mann, and Graham, L.L.P., No. 03-20-00391-CV (Tex....more

Freeman Law

Texas Tax Roundup | March 2022

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Huh whuh? . . . Well . . . Well, howdy! Nice, erm, um well . . . Nice to see ya’ll again at or near this nebulous home home on the range of Texas taxability! Welcome back to another tax-packed installment of all things Texas...more

Freeman Law

Texas Tax Roundup—January 2022

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Hiya folks, and welcome to the inaugural installment of our new series giving you a quick recap of what’s happened in the world of Texas taxes in the month gone by. Let’s get started!...more

Blank Rome LLP

ALJ Upholds Application of New York City UBT Addback to Payments Made for the “Benefit” of Partners

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A recent decision involving the New York City unincorporated business tax addback for payments to partners is an important reminder that the addback may sometimes be applied even for payments that are not made to a partner of...more

Proskauer Rose LLP

Wealth Management Update - June 2021

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June 2021 Interest Rates for Sales to Defective Grantor Trusts, Intra-Family Loans, Split-Interest Charitable Trusts and GRATs - The June applicable federal rate ("AFR") for use with a sale to a defective grantor trust,...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 9

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TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 10, Issue 8

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Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..The New York State Department of Taxation and Finance’s release of revisions to its draft business corporate franchise tax regulations for...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

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There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 5

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Final 2017-18 New York State Budget Bill Enacted - The New York State Budget Bill was enacted by the New York State Legislature and signed into law by Governor Andrew M. Cuomo. S. 2009-C, A. 3009-C. Among the Governor’s...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 4

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ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 3

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ALJ Finds CEO Changed Domicile from New York City to Texas - A New York State Administrative Law Judge has held that the CEO of Match.com (“Match”) changed his domicile from New York to Texas for New York State and City...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 8, Issue 2

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Governor Cuomo Releases 2017-18 New York State Executive Budget - New York State Governor Andrew M. Cuomo released his 2017-2018 Executive Budget, containing an assortment of potentially important tax proposals,...more

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