Noonan's Notes: Hodgson Russ LLP

Timothy Noonan

Hodgson Russ tax attorney Timothy P. Noonan authors "Noonan’s Notes,” a monthly column in Tax Analysts' Tax Notes State. An archive of the articles can be found below.

2024

March 29 - Mass Departure Caught Up to the Tax Department
March 4 - Empire Zone Strikes Back: A New Hope in an Apportionment Battle
January 11 - An Empire Zone Case Strikes Back: Appellate Division Reverses Long-Time Tax Department Policy
January 3 - Massachusetts v. Welch: Taxing a Nonresident on Intangible Stock Sales

2023

December 12 - Strike One in Zelinsky II: New York ALJ Upholds the Convenience Rule in Office Closure Case
November 20 - COVID and New York’s Convenience Rule: Litigation Update
August 9 - The Proposed New York Corp Tax Regs Are Out! And A First Look at the New Passive Investment Customer Rules
July 17 - Fact-Free Residency Case at Tax Appeals Tribunal?
June 28 - Changes to the MCTMT and Limited Partner Taxation in New York
May 8 - An Inside Look at Zelinsky Part II
April 18 - Alcohol and Taxes in New York
April 3 - Moving To a State With No Income Tax? There’s Way More To It Than “Paper” Changes and 183 Days
March 28 - Washington State Capital Gains Tax Upheld by State Supreme Court as Constitutional
March 17 - Obus is over. So What’s Next?
February 20 - An Open Letter to Massachusetts Residents: Here’s How to Move!
January 24 - Another Win for Telecommuters! Missouri Judge Holds St. Louis Improperly Applied Tax to Remote Workers

2022

December 19 - Obus: A Return to Reason in New York's Residency Saga
December 12 - A Blue Wave of High Tax Rates?
November 18 - NYC PTET Update: Election Forms Now Available!
November 18 - Another Big Win in the Statutory Residency Area!
October 24 - New Sourcing Rules for Investment Managers in New York
October 10 - Remote Work Employee Win!
October 6 - New “Jock Tax” Ruling out of Pennsylvania
September 6 - It’s Official: New York City Pass-Through Entity Tax Retroactive to January 1, 2022
July 18 - The Nuts and Bolts of Taxing Stock-Based Compensation in New York
July 1 - A Huge Win in Obus
May 10 - It’s Official: Pass-Through Entities Now Have Until September 15 to Make the 2022 New York Pass-Through Entity Tax Election
May 9 - The Nuts and Bolts of NYC's New Passthrough Entity Tax
May 4 - New York State Looks to Adopt Final Corporate Tax Reform Regulations
May 3 - Second Chance for Pass-Through Entities that Missed New York’s March 15 Election Deadline!
April 11 - BREAKING!!! 2023 Budget Bill Expands New York’s Pass-Through Entity Tax for Some (But Not All) Resident S Corporation Shareholders
April 1 - New Guidelines and a New Rule for New York Residency Audits
March 9 - 2021 and 2022 PTET Due Dates Upcoming!
March 3 - Washington State Capital Gains Tax Struck Down by Judge As Unconstitutional
January 27 - Proposed Changes to NYS’s Brownfield Cleanup Program Contained in the Governor’s Executive Budget
January 24 - NY PTET Update: Treatment of Guaranteed Payments
January 17 - 2021 New York Tax Cases: A Year in Review
January 14 - New Audit Guidelines in New York: A Change to the 11-Month Rule

2021

November 18 - To Give Or Not To Give, That Is The Question: New York State’s Rules on Charitable Giving and Domicile Determination
November 11 - Important Information for PTE Taxpayers: Requirements for 2021 Extension Payments
November 5 - What are Substantially Similar Taxes?
October 18 - The Nuts and Bolts of New York's 548-Day Rule, Revisited
October 13 - Hurricane Forces New York to Extend Some Deadlines
October 7 - Important Updates for New York’s Pass-Through Entity Tax
October 6 - Courts Ruled on the SALT Cap Litigation
August 30 - New York vs. New Jersey: Sorting Through Post-Pandemic Resident Credits
August 26 - New York Issues Guidance on Pass-Through Entity Tax
June 7 - The Nuts and Bolts of New York’s New Passthrough Entity Tax
May 31 - New York's Convenience Rule: Under the COVID Microscope
April 15 - Finally, Connecticut Joins the Telecommuting Guidance Party
March 17 - A New Type of Pied-à-Terre Tax: A Surcharge on Non-Primary Owners
March 1 - COVID-19: The Year of Great Migration
February 12 - New York Legislative Tracker: February 12, 2021 Update
February 8 - New York Legislative Tracker: Budget Proposal - February 8, 2021 Update
February 3 - New York Legislative Tracker: Budget Proposal - February 3, 2021 Update
January 22 - New York Legislative Tracker: January 22, 2021 Update
January 21 - UPDATE: Can a New York Resident Claim a Resident Tax Credit for the Connecticut Pass-through Entity Tax? New Legislation Provides An Answer
January 21 - New York Tax Rates Going Up, With a Twist
January 21 - Change on the Horizon? - New York Budget Bill Proposes Pass-Through Entity SALT Cap Workaround
January 14 - New York Legislative Tracker: January 14, 2021 Update
January 7 - New York Legislative Tracker: January 7, 2021 Update

2020

December 31 - “Of Interest” Proposed Legislation In New York: What’s Pending and What It Could Mean
December 21 - IRS Blesses SALT Cap Workaround: What’s Next in 2021?
December 18 - NY Tax Talk: 2020 in the Rearview
November 10 - Clarity at Last – IRS Indicates Forthcoming Approval of SALT Cap Pass-Through Entity Workarounds
October 28 - New Trend in Residency Audits?
October 22 - New York Tax Department Finally Issues Guidance on COVID-19 Telecommuting
October 16 - NY Tax Talk: Trump Tax Returns, Revenue Rebound, Reform
September 17 - Taxing Times to Be a Telecommuter: Convenience Rules During COVID-19
August 10 - State Guidance related to COVID-19: Telecommuting Issues
July 13 - Taking the Stink Out of New York's Cheeseboard Rule
June 29 - Another (!) Note on Cell Phone Records
June 22 - Telecommuting During COVID-19: One Headache After Another
June 12 - New York Confirms Estimated Tax Payment Due June 15
June 10 - Shining a Light on Covid-19 Telecommuting and NYC’s UBT: A Windfall for Hedge Funds and Other Professional Services Firms?
May 21 - New York Governor Extends Digital Signature Authorization
April 27 - Setting the Table on Allocation and Apportionment in New York
April 23 - Day Count Relief from the IRS: Is New York Listening?
April 17 - New Tax Department Guidance on Digital Signatures in the COVID-19 Era
April 13 - COVID-19 Impact on New York Residency, Day Counts, and Allocation
April 6 - Digital Taxation: The Source of the Problem
March 30 - The Nuts and Bolts of Nonresident Wage Allocation in New York
March 23 - Hodgson Russ Client Alert Repost: COVID-19 Federal, State and Local Tax Employer Relief Efforts Update
March 23 - Coronavirus/COVID-19 Update from the NYS Division of Tax Appeals
February 24 - Apple Gets Bit by New York Sales Taxes
January 28 - New Jersey Enacts Pass-Through Entity SALT Cap

2019

December 27 - Democratic House Passes Short-term SALT Cap Repeal Bill
December 16 - Looking Ahead in New York Taxes: Ending the Vacation Home Debate
December 16 - Farewell 2019, Hello 2020!
December 9 - States File Appeal in SALT Cap Litigation
November 26 - Leave the Attorneys & Accountants Out of It: Minnesota Department of Revenue Tweaks Domicile Rules for Individual Income Tax Purposes
November 25 - Another New York False Claims Case in the News
November 25 - Is the Pied-à-Terre Tax Coming Back?
November 21 - Corporate Partners: Beware of New York’s Changes to its Draft Regulations!
November 18 - Payments to Partners Under NYC's Unincorporated Business Tax
September 23 - Down the Rabbit Hole: N.Y. Updates Corporate Tax Apportionment Rules
July 29 - Federal Opportunity Zones and New York's Accrual Rule
July 15 - Federal Opportunity Zones and New York's Accrual Rule
July 8 - Tax Return Disclosure Legislation
June 24 - Tax Return Disclosure Legislation
May 6 - Burying New York's 'Only Reasonable Construction' Standard
April 22 - Residency Audits, Day Counts, and Your Cell Phone
April 1 - Should States Embrace GILTI?
February 25 - New York Had Wayfair Guidance All Along!

2018

December 17 - 2018 in Review: Responses to Federal Tax Changes
December 17 - Justice Kennedy's Tax Legacy: A Lot of Wayfair and a Little Wynne
November 12 - The Nuts and Bolts of Connecticut's New Passthrough Entity Tax
October 19 - Checking in on New York's Division of Tax Appeals
July 9 - The Art of Taxing Luxury Items in New York
May 28 - Hedge Funds and Deferred Management Fees: 2017 State Tax Gold?
April 6 - Mays v. New York: A New Framework for an Old Test
February 26 - Full-Court Press: Multistate Tax Issues Facing Professional Athletes

2017

December 11 - The Power of Testimony in New York Domicile Cases
October 30 - Online Marketplaces: Who Sold What to Whom and Where?
September 4 - Taxing Ride- Sharing Services in New York
June 26 - Hedge Funds, Apportionment, and Whistleblowers in New York
June 19 - Market-Based Sourcing in New York and Beyond
May 8 - The Nuts and Bolts of New York Sales Tax on Interior Design
March 13 - A Quick Look at Proposed Legislation in New York
March 6 - Gaied v. New York: 3 Years Gone

2016

December 19 - The Nuts and Bolts of New York's Resident Credit
October 17 - Breaking Up Is Hard to Do: Nonresidents' Role in the New York Economy
September 5 - One 10-Year Step for the Column, One 25-Year Leap for the Magazine
August 22 - Trust Us: New York's Residency Rules For Trusts Are Complicated
July 11 - Could Ohio’s Latest Due Process Case Spell Trouble for New York?
June 13 - Litigating a New York Tax Case, Volume 4: Tax Litigation in the New York Courts
June 3 - Contributor, New York Residency and Allocation Audit Handbook (2016), CCH
May 9 - Litigating a New York Tax Case, Volume 3: The Administrative Appeals Process
May 2 - 2016-17 New York State Budget
March 14 - Litigating a New York Tax Case, Volume 2

February 29 - Litigating a New York Tax Case, Volume 1: The Audit Process

2015

December 14 - Sales Tax in New York State: A Year in Review
November 30 - A Foreign Language? Residency Rules With an International Spin
November 2 - A New Trump Card for New York Residency Audits?
August 10 - The Emperor Strikes Back in Caprio
June 29 - The Nuts and Bolts of New York’s Sales Tax Rules for Contractors
June 1 - Pay to Play? How States Handle Signing Bonuses for Athletes
May 17 - New York Budget Bill: The Sequel
March 16 - Behind the Numbers: A Look Into New York’s Division of Tax Appeals
February 23 - Highlighting Multiyear Allocation Difficulties in New York
February 9 - What’s Up With New York Auditing Wall Street for Sales Tax?
January 19 - State of Confusion: Sourcing Financial Services Receipts

2014

October 27 - The Nuts and Bolts of a New York Residency Audit, Revisited
July 21 - New York Tax Department's Response to Gaied Misses the Mark
June 23 - New York Ruling Raises Questions About The Taxation of Cloud Computing Services
May 19 - The Goods on Gaied: What It Means, From the Front Lines
March 31 - The Nuts and Bolts of Property Tax Exemptions for Nonprofits
March 3 - New York Budget Bill Proposes Many Corporate Tax Changes

February 10 - New York City Residents May Be Asked to Pay a Little More in Taxes

2013

December 17 - Empire Zone Litigation - Taking the 'Reduction' Out of the Tax Reduction Credit
November 5 - Tax Collector in Mirror Is Closer Than It Appears: New York Acts to Suspend Taxpayers’ Driver’s Licenses
October 4 - Fixing New York's Scaffold Tax
September 30 - Changes to New York’s Royalty Addback Rules
June 24 - New York Litigation, Part 2: Recent Headlines From the New York Courts
May 2 - The Amazon Decision: A New Nexus Standard for the Internet Age?
April 15 - New York Tax Litigation, Part 1: From the Administrative Forum
March 4 - Hedge Funds and Deferred Management Fees: State Taxes

2012

December 10 - Repairing New York’s Capital Improvement Rules
October 15 - New Nonresident Audit Guidelines
August 20 - Nuts-and-Bolts Answers on Cloud Computing
June 11 - What Retirement Income Is Exempt From State Taxes?
April 30 - Resident Evil Part 3: Fighting Back With New Technology
April 16 - No Repose on 338(h)(10) Elections: New York's Retroactive 'Correction'
April 10 - Heads They Win, Tails You Lose: Resident Credit Problems
February 20 - The Nuts and Bolts of Capital Improvements in New York

2011

December 12 - New York Updates: Little Changes Lead to Big Improvements
October 17 - Taxing Groupon-Type Coupons: New York Tax Department Guidance
September 19 - The Nuts and Bolts of Sales Taxation of Investment Research
July 18 - Residency Ruling Raises Stakes for Owning an ‘Abode’ in New York
May 26 - An Easier Fix to New York’s Statutory Residency Problem?
April 11 - Sales Tax Considerations in an Asset Purchase
March 8 - The Nuts and Bolts of New York’s 548-Day Rule
February 15 - Calling All Tax Whistleblowers — New York Wants You!

2010

December 13 - The Multistate Tax Quandary for Professional Athletes
October 22 - Information Services: Taxation by Administrative Fiat in New York
October 8 - A New Day Dawns for Determining What Constitutes a New York Day
July 28 - More Battles in New York's Empire Zones
June 29 - Multistate Withholding Tax: The Next Big issue in State Tax Practice
May 10 - New York Issues New Nonresident Audit Guidelines
April 12 - The Continuing Saga of Unlimited Liability Companies in New York
March 29 - Hotels Win Big on Taxation of Loyalty Programs
February 26 - The Ins and Outs of New York Nonresident Allocation Issues

2009

December 7 - Giving Exemption Certificates Their Due
November 17 - The Nuts and Bolts of Sales Tax Issues for Exempt Organizations
September 29 - Delivering New York's Voluntary Disclosure Gold
August 26 - Tough Measures for Tough Times — New York's Budget Bill
July 9 - Striking Back on Empire Zones
May 13 - New York Section 338(h)(10) Elections on the Sale of S Corporation Stock
April 6 - Merchants and Affiliates Struggle to Navigate New York's 'Amazon Law'
March 19 - Taxation of Internet-Based Software Sales
February 19 - New York Governor's Tax Proposals for Fiscal 2010

2008

December 22 - The Nuts and Bolts of a New York Residency Audit
November 10 - An End to the Temporary Stay Test in New York?
September 29 - Identifying and Resolving a New York Tax Problem Just Got Tougher
August 15 - Watch Out for New York's Accrual Rule
June 30 - Multistate Taxation of Stock Option Income - Time for a National Solution?
June 2 - Updates and Practice Notes on Recent New York Developments
April 28 - Day Counts and the Importance of Testimony in Statutory Residency Audits
February 18 - Sea of Changes in New York Governor's Tax Proposals
January 21 - The Ins and Outs of a Sales Tax Audit

2007

November 19 - Practical Difficulties In Streamlining the Sales Tax
July 30 - New York Practice Issue - More Developments in the Temporary Stay Area
June 25 - U.S. Supreme Court's Decision to Hear Municipal Bond Case Raises Questions
May 7 - New York Budget Increases Taxes by $300 Million
April 23 - Stock Options - The New York Tax Department's Effort to Undermine Stuckless
March 19 - A Very Good Knight for Taxpayers
February 19 - Litigating a New York Case from Start to Finish