In This Issue:

- Important Changes at NYS and NYC Tax Agencies

- Court of Appeals Upholds Constitutionality of Taxing Nonresidents on Gain from S Corporation Stock Sale in Two Separate Decisions

- NYC Tribunal Upholds Denial of UBT Deduction for Management Fee Paid to Corporate Partner

- Tribunal Affirms ALJ Decision Rejecting Increase in Foreign Bank’s Allocation of Income to New York State

- Conveyance of Condominium Units from LLC to Its Members Qualifies as “Mere Change of Identity or Form”

- Insights in Brief

- Excerpt from Important Changes at NYS and NYC Tax Agencies:

In June 2015, Jerry Boone was appointed as the new Commissioner of the New York State Department of Taxation and Finance. Commissioner Boone was most recently President of the New York State Civil Service Commission and New York State Department of Civil Service. He began his career in New York State government with the Attorney General’s Office as an Assistant Attorney General, ultimately serving as the State’s Solicitor General. In the private sector, he was corporate in-house counsel and risk compliance officer for a large casino and hospitality company. He replaces former Commissioner Thomas Mattox, who resigned earlier this year.

Glenn Newman has retired as President and Commissioner of the New York City Tax Appeals Tribunal and New York City Tax Commission, effective May 29, 2015. Mr. Newman thus ends 34 years of New York City public service, which included positions as Chief of the Tax and Bankruptcy Division of the New York City Law Department and as Deputy Commissioner of Audit and Enforcement for the New York City Department of Finance. Mr. Newman was the first City official to simultaneously head both the City Tax Appeals Tribunal and the Tax Commission. As we went to press, New York City Mayor De Blasio named Ellen E. Hoffman, currently a Commissioner at the City Tax Tribunal, to succeed Mr. Newman as President of the Tax Commission, subject to City Council confirmation. Ms. Hoffman has also been serving as Acting President of the City Tax Tribunal since Mr. Newman’s retirement.