MoFo New York Tax Insights - Volume 8, Issue 3

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 personal income tax purposes, despite his maintenance of substantial connections to New York during the years in question. Matter of Gregory Blatt, DTA No. 826504 (N.Y.S. Div. of Tax App., Feb. 2, 2017). The ALJ rejected the Department of Taxation and Finance’s argument that Mr. Blatt’s ownership of an apartment in New York City, and the substantial renovations made to the property, were indicative of his intent to remain domiciled in New York City.

Facts. Gregory Blatt was originally from Massachusetts and first moved to New York City in 1992 to attend Columbia Law School. Beginning in 2003, Mr. Blatt began work as the General Counsel for InterActiveCorp (“IAC”), a publicly traded corporation that owned multiple large Internet companies. In 2006, Mr. Blatt executed an employment agreement with IAC, pursuant to which his title was “Executive Vice President, General Counsel & Secretary,” and specifying that his principal place of employment was in New York City. As General Counsel of IAC, Mr. Blatt oversaw a legal department of approximately 50 people.