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Noonan’s Notes Blog

About This Blog

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 and multistate tax law. Noonan's Notes Blog is a winner of CreditDonkey's Best Tax Blogs Award 2017.


Timothy Noonan 
Brandon Bourg 
Mario Caito
Ariele Doolittle
Joseph Endres
Daniel Kelly
Katherine Piazza McDonald
Elizabeth Pascal 
Emma Savino 
Joseph Tantillo
Craig Reilly
Andrew Wright 

Showing 30 posts from 2017.

Not Fake News: Congress Shuts Down Pre-payment of 2018 State Income Taxes!

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On Friday afternoon, we emailed many clients and friends regarding the possibility of a “last chance” to claim a disappearing federal income tax deduction by paying 2018 state income tax estimates at the end of 2017. Apparently some of you didn’t get the email until Sunday. Sad! More on that below.

New York State Tax Department Releases 2018 Estimated Tax Vouchers

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Due to the likely elimination of almost the entire SALT deduction in 2018, this could be the last opportunity for taxpayers to pay state and local taxes and still ensure a full federal tax deduction. Keep reading to learn more.

The Federal Tax Reform Proposals and the Likelihood of a Disappearing SALT Deduction

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Here's what you need to know about the likelihood of a disappearing SALT deduction.

Topics: Tax Reform

The Annual Report of the Division of Tax Appeals and Tax Appeals Tribunal

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On October 17, 2017, the New York State Division of Tax Appeals and Tax Appeals Tribunal (collectively “DTA”) submitted its annual report to the Governor and heads of the Senate and Assembly for the 2016-17 fiscal year. Numbers-wise, we don’t see a tremendous change over last year in the outcomes of Administrative Law Judge and Tax Appeals Tribunal cases.

Drips and Drops on Taxing Hedge Fund Managers’ Deferred Comp

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For years, there have been whispers about a big 2017 tax issue for hedge-fund managers. What’s the deal?

Market-Based Sourcing and Beyond: Be on the Lookout for New State Tax Issues in the Corporate Tax World

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Just when you thought you knew everything there was to know about multistate corporate income tax apportionment, the states start switching up the rules!

Gaied Legislation Proposed for NYS Statutory Residency

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Last Friday, members of the NYS Legislature introduced a bill aimed at clarifying the definition of “permanent place of abode” under Tax Law § 605(b)(1)(B) for statutory residency purposes. Under that statute, a person is generally taxable as a resident if they meet a two-pronged test: (1) maintain a “permanent place of abode” in New York and (2) spend more than 183 days in New York.  

Regarding Hurricanes Harvey and Irma and their Impact on New York Residency

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Clients who are domiciled in Texas, Florida, and US Virgin Islands may end up spending additional time in New York this year, due to Hurricanes Harvey or Irma. Those affected might be concerned about the impact of that additional New York time on their New York residency situation. Clients should be aware that the New York State Department of Taxation of Finance has not put out any information to taxpayers affected, or potentially affected, by these storms. To our knowledge, the Department has never issued an official policy regarding the treatment of days spent in New York due to a mandatory evacuation from a primary residence in another state, or damage to that residence.

New York Tax Powers of Attorney: There’s an App for That…and a New Form

For years, practitioners and taxpayers have struggled with the cumbersome, four-page power-of-attorney form that the New York Tax Department has required taxpayers to use when they wanted to appoint a representative to help them with their tax matter.

But this week, the NYS Tax Department rolled out a new web application where POAs can be filed online.

Love Conquers All in New York Domicile Case

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Last week, another great domicile case was issued by New York’s Division of Tax Appeals. The case, entitled Matter of Patrick, chronicled a movie-esque love affair between long-lost high school sweethearts and—more importantly for our purposes—another win for a taxpayer in a change-of-domicile case. We also covered this case in our TiNY Blog.

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