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

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

“If You Don’t Make It There, You Can’t Make It Anywhere:” New York’s Zero Manufacturing Rate Requires New York Property

A New York State administrative law judge (ALJ) found that Raytheon did not qualify for the state’s zero percent tax rate for manufacturers or the reduced tax rate for qualified emerging technology companies (QETCs)....more

“Primary Function” Test Propels Yet Another Service Provider to Victory in New York Sales Tax Case

An administrative law judge in the New York State Division of Tax Appeals rejected the state’s position that a taxpayer providing a web-based service which allowed clients to identify effective and ineffective messaging...more

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