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MoFo New York Tax Insights Volume 11, Issue 2

Welcome to the latest issue of New York Tax Insights. In this issue we cover: Decisions from both the Appellate Division and the NYS Tax Appeals Tribunal holding it was unconstitutional to apply the April 2009 QEZE...more

MoFo New York Tax Insights Volume 11, Issue 1

Welcome to the latest issue of New York Tax Insights. In this issue we cover: • Our annual review of the developments we considered the Top 10 New York tax highlights in the past year (on page 1). •Three separate ALJ...more

MoFo New York Tax Insights - Volume 10, Issue 10

Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..A recent ALJ decision holding that a vacation home owned by a New Jersey domiciliary and located in upstate New York, hundreds of miles from...more

MoFo New York Tax Insights - Volume 10, Issue 9

TRIBUNAL AFFIRMS DECISION SOURCING “OTHER BUSINESS RECEIPTS” TO WHERE THE WORK WAS PERFORMED - After three non-precedential Administrative Law Judge decisions—and well after the statute in question has been replaced by new...more

MoFo New York Tax Insights - Volume 10, Issue 8

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

New York Revises Draft Apportionment Regulation on Specified Services That Will Affect Many Businesses, Including the Financial...

The New York State Department of Taxation and Finance has made several significant revisions to its draft corporate income tax regulation for the sourcing of receipts from other services and other business activities. Draft...more

MoFo New York Tax Insights - Volume 10, Issue 7

NEW YORK’S HIGHEST COURT UPHOLDS SALES TAX ON INFORMATION SERVICES AND INTERPRETS TAX EXCLUSION IN FAVOR OF DEPARTMENT - Reversing a decision of the Appellate Division, a sharply divided New York Court of Appeals has upheld...more

New York State Governor Signs Legislation Exempting 95% of GILTI

The New York State Legislature has passed, and New York Governor Cuomo has now signed, legislation which provides for the exclusion of 95% of a corporation’s gross global intangible low-taxed income (“GILTI”) from its New...more

MoFo New York Tax Insights: Volume 10, Issue 6

Welcome to the latest issue of New York Tax Insights. In this issue we cover: ..A Third Department decision denying deductibility of insurance premiums paid to a captive insurance company, upholding the decision of the New...more

MoFo New York Tax Insights - Volume 10, Issue 5

2019-20 NYS BUDGET ENACTED, INCLUDING REAL ESTATE TRANSFER TAX INCREASES - On April 12, 2019, Governor Andrew M. Cuomo signed into law the New York State Budget Bill for the State’s 2019-20 fiscal year, which began on April...more

MoFo New York Tax Insights - Volume 10, Issue 4

NEW YORK STATE 2019-20 BUDGET BILL ENACTED - As we went to press, the New York State Legislature passed the New York State Budget Bill for 2019-20, containing several new and important tax provisions. S. 1509-C/A. 2009-C....more

MoFo New York Tax Insights - Volume 10, Issue 3 (March 2019)

NYC ALJ UPHOLDS TAX ON CAPITAL GAIN BASED ON NYC PRESENCE OF INVESTMENT THAT WAS SOLD - A New York City Administrative Law Judge has upheld the Department of Finance’s imposition of General Corporation Tax (“GCT”) on a...more

MoFo New York Tax Insights - Volume 10, Issue 2

GOVERNOR RELEASES PROPOSED 2019-20 NEW YORK STATE EXECUTIVE BUDGET - On January 15, 2019, New York State Governor Andrew M. Cuomo released the New York State 2019-20 Executive Budget, applicable to the State’s fiscal year...more

2019-20 New York State Executive Budget Released by Governor Cuomo

On January 15, 2019, New York State Governor Andrew M. Cuomo released his 2019-20 Executive Budget. It contains several potentially important tax proposals, including the following...more

Pennsylvania Says Receipts from Hedging Transactions Are Excluded from Sales Factor

On January 4, 2019, the Pennsylvania Department of Revenue issued Corporation Tax Bulletin 2019-01 taking the position that receipts from hedging transactions, including those of a securities dealer, should be excluded from...more

MoFo New York Tax Insights - Volume 10, Issue 1

THE TOP 10 NEW YORK TAX HIGHLIGHTS OF 2018 - Once again, we present our annual list of what we considered the Top 10 New York tax highlights of 2018. 1. Court of Appeals Agrees to Hear Tax Department’s Appeal Involving...more

MoFo New York Tax Insights - Volume 9, Issue 12

A SECOND APPELLATE COURT UPHOLDS THE CONSTITUTIONALITY OF NEW YORK’S STATUTORY RESIDENCY SCHEME - The New York Appellate Division, Third Department, has upheld the dismissal of a declaratory judgment action brought by...more

California FTB Ruling Addresses Definition of a Financial Corporation

A recently issued California Franchise Tax Board Chief Counsel ruling provides important guidance on the scope of a regulation regarding qualification as a “financial corporation” for California corporation franchise tax...more

MoFo New York Tax Insights - Volume 9, Issue 11

NYS TRIBUNAL REVERSES ALJ AND HOLDS THAT BOND RATING AGENCY IS ENTITLED TO REFUND OF SALES TAX - The New York State Tax Appeals Tribunal reversed the determination of an Administrative Law Judge and held that a securities...more

MoFo New York Tax Insights - Volume 9, Issue 10

STATE COURT REFUSES TO DISMISS ACTION CHALLENGING CONSTITUTIONALITY OF NYC PROPERTY TAX SYSTEM - The Supreme Court, New York County, has denied motions to dismiss an action seeking relief for alleged inequalities in the...more

MoFo New York Tax Insights - Volume 9, Issue 9

APPELLATE COURT REVERSES TRIBUNAL AND GRANTS QEZE PROPERTY TAX CREDITS - The Appellate Division, Third Department, has reversed a decision of the New York State Tax Appeals Tribunal that had denied a refund of personal...more

NY Lawsuit Challenging Federal SALT Cap: The Complaint

New York state, together with the states of New Jersey, Connecticut and Maryland, has brought suit in federal district court seeking to invalidate on constitutional grounds the $10,000 cap on state and local tax, or SALT,...more

MoFo New York Tax Insights - Volume 9, Issue 8

APPELLATE COURT DISMISSES CONSTITUTIONAL CHALLENGE TO NEW YORK’S STATUTORY RESIDENCY SCHEME - The New York Appellate Division, First Department, finding that the U.S. Supreme Court’s 2015 decision in Comptroller of the...more

MoFo New York Tax Insights - Volume 9, Issue 7

APPELLATE DIVISION HOLDS THAT BANK MUST APPLY NOLS IN YEAR IT WAS TAXED ON NON-INCOME BASE - The Appellate Division has held that a taxpayer was required to use its net operating loss (“NOL”) carryforward to decrease its...more

MoFo New York Tax Insights - Volume 9, Issue 6

DRAFT BILL RELEASED IMPLEMENTING A NEW YORK STATE UNINCORPORATED BUSINESS TAX - The New York State Department of Taxation and Finance has released a “discussion draft” of a bill that would implement a New York State...more

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