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
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
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
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
Massachusetts is taxing nonresidents who are working outside Massachusetts due to COVID-19. Seems unfair? Well New Hampshire agrees and has asked the US Supreme Court to allow it to bring suit against Massachusetts. Matt...more
Drums. Do you hear them? Along the western shore of the Hudson River. It seems that the unrest which began in New England earlier this year is spreading into the Mid-Atlantic States. The owner of a New York business that...more
With the unfortunate emergence and rapid spread of the coronavirus (COVID-19) pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year....more