2004-2006 Articles

IRS targets employees of foreign embassies and international organizations: Dec-15-2006 — According to the IRS, a significant number of employees and former employees of foreign embassies, foreign consular offices, and international organizations in the United States fail to fulfill their U.S. income tax responsibilities.
New York stock option tax rules invalidated: Oct-03-2006 — The New York State Department of Taxation and Finance's defeat in a recent case promises to change significantly the way in which New York State can tax stock option income earned by nonresidents.
New York's revised convenience rule provides some clarity and continued controversy: Oct-03-2006 — Just when the controversy surrounding New York's "convenience of the employer" rule seemed to be all but dead, the New York State Department of Taxation and Finance gave us another reason to write about it.
Refund opportunity for nonresidents with stock option income: Aug-29-2006 — A recent New York Tax Appeals Tribunal ruling may present a refund opportunity for nonresidents who paid tax to New York on stock option income using the “grant-to-exercise” rule.
New York State sales tax issues for the construction contractor: Aug-01-2006 — State sales taxes are tricky, especially in the construction industry, and New York is no exception.
The Imposition of Unlimited Liability On Limited Partners and Members of LLCs in New York: Dec-07-2005 — According to the interpretation of the sales tax statute by the NYS Dept. of Taxation and Finance, there is no limit whatsoever to the liability of a limited partner or LLC member for the sales and use taxes that should have been collected by the entity.
Tax Alert: Katrina Emergency Tax Relief Act of 2005 (KETRA): Nov-04-2005 — As a result of this temporary provision, individual taxpayers can almost totally eliminate their federal taxable incomes for 2005.
New York Tax Appeals Tribunal Issues Stock-Option Decision: Jul-22-2005 — The New York State Tax Appeals Tribunal has rejected New York's long-standing policy on the treatment of a nonresident's stock-option income.
IRS issues new regulations for partnership withholdings: Jul-14-2005 — This article by Hodgson Russ associate Marla Waiss was originally published in The Buffalo Law Journal, vol. 77, no. 56, July 14, 2005. Reprinted with permission.
Court of Appeals Upholds the "Convenience of the Employer Doctrine" in Matter of Huckaby: Mar-30-2005 — The Huckaby Court upheld the application of the controversial “convenience of the employer doctrine,” which in the Huckaby case was applied to tax 100% of the wages of a telecommuter who worked for a New York employer from his home in Tennessee.
Proposed rules permit tax-free cross-border mergers: Mar-24-2005 — The IRS recently issued proposed regulations allowing certain mergers and consolidations effective under foreign law to qualify as tax-free A reorganizations.
Temporary Stays in New York: A New Set of Rules in Residency Audits?: Mar-21-2005 — The tax department now takes a more stringent view of the temporary assignment rules and has coupled that shift in policy with an increased focus on the issue in residency audits.
US Tax Opinions and Practices: May-14-2004 — The US Treasury recently proposed changes to the regulations that govern practice before the IRS. The proposals hope to restore, promote, and maintain the public's confidence in the honesty and integrity of professionals who provide tax advice.
Falberg Adds Clarity to New York's Part-Year Allocation Rules: Jan-29-2004 — One of the hot topics in New York tax law over the past few years has related to a part-year resident's reporting of flow-through income. This issue has ben the subject of much debate and litigation.

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