Noonan’s Notes Blog

The Pied-à-terre Tax Has Landed!

Noah S. Chase, Lauren E. Austin, Timothy P. Noonan — Thu, 28 May 2026 09:00:01 -0400

We told you it was coming. Back in April, we covered Governor Hochul’s proposal to impose a pied-à-terre surcharge on NYC second homes, noting that the details – rates, methodology, administration – were still to come. With the Governor’s final budget coming into place, the provisions of the new tax are finalized.

A Pied-à-terre Tax in NYC: Part-Time Living, Full-Time Taxing?

Noah S. Chase, Timothy P. Noonan — Wed, 15 Apr 2026 09:00:02 -0400

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?

Mayor Mamdani, Property Taxes, and the Shrinking Margin for Staying in New York City

Andrew W. Wright, Joseph F. Tantillo — Tue, 24 Feb 2026 09:00:03 -0500

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.

When Deference Runs Out of Gas: Third Department Puts the Tribunal in Reverse in Gelco

Timothy P. Noonan, Noah S. Chase — Wed, 18 Feb 2026 09:00:04 -0500

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.

NYC’s First Batch of Corporate Tax Regulations

Kevin R. Harkins, Timothy P. Noonan — Thu, 22 Jan 2026 09:00:05 -0500

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.

By Their Words You Shall Know Them

Noah S. Chase, Timothy P. Noonan — Tue, 20 Jan 2026 09:00:06 -0500

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.

Only A Matter of Time in the Matter of Hoff

Noah S. Chase, Timothy P. Noonan — Mon, 15 Dec 2025 09:00:07 -0500

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).

Hinging on a Comma? Another Big Win for Taxpayers in a NYC UBT Case

Kevin R. Harkins, Timothy P. Noonan — Fri, 21 Nov 2025 09:00:08 -0500

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.

Adjudicating Tax Disputes in New York: Practice and Procedure before the Division of Tax Appeals and Tax Appeals Tribunal

Noah S. Chase, Timothy P. Noonan — Mon, 17 Nov 2025 09:00:09 -0500

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!

Were you Lying Then or Are you Lying Now? Taxpayers Lose New Hampshire Residency Case

Peter R. Calleri, Timothy P. Noonan — Mon, 13 Oct 2025 09:00:10 -0400

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.