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Noonan’s Notes Blog is written by a team of Hodgson Russ tax attorneys led by the blog’s namesake, Tim Noonan. Noonan’s Notes Blog regularly provides analysis of and commentary on developments in the world of New York tax law.

New York City’s budget gap continues to raise questions as different government leaders suggest potential solutions. And just yesterday, with budget negotiations stalled, Governor Hochul threw out a new idea: the imposition of a pied-à-terre tax in NYC. This isn’t the first time such an idea has been bounced around in Albany. So, what does this mean, and what are the likely consequences? 

New York City may be headed toward a broad-based increase in local property taxes, one of the few tax increases that doesn’t require approval from Albany. Mayor Zohran Mamdani recently proposed a roughly 9.5% property tax hike as a contingency plan to close a multibillion-dollar budget gap if state lawmakers decline to raise income tax on high earners. While the political debate has focused on competing visions of taxation and spending, the practical reality is simple: when property taxes rise, the people who live in, own, or invest in New York real estate bear the cost. For taxpayers, this proposal is less an abstract fiscal policy and more a direct hit to household and business finances.

Whenever the Third Department tells the Tax Appeals Tribunal that it got a decision wrong, we make sure to pay attention. This time, the Third Department went to the history section of their local library to check out some bill jackets – just in case the statutory language wasn’t clear enough. The case is Gelco Corporation v. New York Tax Appeals Tribunal, and here’s the rundown.

Despite the BCT being in place for over 10 years, it was only recently, on October 16, 2025, that the New York City Department of Finance (the “Department”) published the first set of proposed regulations for the BCT.  These proposed BCT regulations are largely based on the State’s regulations, but there are some significant differences concerning corporate limited partners which we will highlight below.

Another installment in the bundled sales and services saga.  The Third Department recently released its opinion in the Matter of Beeline.com v. New York Tax Appeals Tribunal, and we have distilled it down for your enjoyment here.

It’s not that often that we get to see a real bread-and-butter domicile case coming out of New York’s Tax Appeals Tribunal, but we recently got a good one in Matter of Hoff, DTA No. 850209 (N.Y. Tax App. Trib. Oct. 9, 2025).

Just this week, the New York City Tax Appeals Tribunal Appeals Division upheld that decision, in Matter of A&E Television Networks, LLC, TAT(E) 20-32 (UB), handing the taxpayer a significant win—and hopefully curbing the City’s aggressive enforcement efforts more generally in UBT cases.  

On Thursday, November 13, 2025, the New York State Bar Association’s Tax Section put together a one-hour panel event focused on discussing the “Practice and Procedure” of adjudicating tax disputes in New York.  We listened in and thought you’d like to hear about it!

Over the summer, the New Hampshire Supreme Court took up our favorite issue—state tax residency—in Morris v. Commissioner, New Hampshire Department of Revenue Administration. The case addressed whether the Taxpayers were residents of New Hampshire for a period of time in 2017.

Time Warner Cable Information Services (NY), a Charter affiliate, provided bundled VoIP services (local, long-distance, international) in New York from March 1, 2014, to February 28, 2017. As a telecom provider, they had to pay the Federal Universal Service Fund (FUSF)—a federal surcharge based on interstate (and international) revenue—though providers pass this cost to customers as a line item.

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