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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.

Contributors

Timothy Noonan 
Ariele Doolittle
Joseph Endres
Daniel Kelly
Elizabeth Pascal 
Craig Reilly
Andrew Wright 

Photo of Noonan’s Notes Blog Christopher L. Doyle
Partner, State & Local Tax Practice Leader
cdoyle@hodgsonruss.com
716.848.1458
View Bio »
Chris is in the firm's State & Local Tax (SALT) Practice. His practice spans most tax matters, but focuses primarily on New York State and New York City business taxes …

Showing 10 posts by Christopher L. Doyle.

Five Organizations File Amicus Briefs Urging the Supreme Court of the United States to Hear Taxpayers' Lawsuit

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On June 24, Hodgson Russ LLP filed petitions for certiorari with the Supreme Court of the United States (“the Supreme Court”) in two cases involving the double taxation of taxpayers who lived in another state but were “statutory” residents of New York because they had a place to live in New York and were in New York 183 days or more. The cases are titled: Samuel Edelman and Louise Edelman, Petitioners v. New York State Department of Taxation and Finance, et al. (“Edelman”) and Richard Chamberlain and Martha Crum, Petitioners v. New York State Department of Taxation and Finance, et al. (“Chamberlain”).

Quill Overturned!

Wow.

This morning the U.S. Supreme Court sent a shockwave through the Internet—and the SALT community—by issuing its long-awaited decision in the South Dakota v. Wayfair case and resoundingly overturning the Quill physical-presence nexus standard that had been the law of the land for sales tax purposes for the past several decades.

Wasn’t the U.S. Constitution Written in Just 116 Days?

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On March 7, 2018, the NY Tax Department issued its first income tax advisory opinion of the year. The content of the advisory opinion, a review of the rules governing the timing of the tax credits associated with the state’s Brownfield Cleanup Program, isn’t particularly noteworthy. What struck us here at Noonan’s Notes, and made the opinion blog-worthy, is the timing of the opinion. Though the Tax Department has many functions (e.g., return design and processing, enforcement/audit, tax collection, etc.), this opinion may illustrate that additional resources should be allocated to its interpretation and education functions.

Better Late than Never? New York Issues Guidance on Hedge Fund Deferred Compensation

For years we’ve been following a ticking income tax time bomb of sorts, dealing with a big 2017 issue for hedge fund managers receiving deferred income. We first started talking about this in 2013 (click here for the article) and followed-up on it a few times later (including here), wondering how states would react to all this. But up until last week, we’ve heard nothing from the New York tax department on the issue.

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

Corporate Tax Reform FAQs

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Since the new corporate tax reform went into effect on January 1, 2015, the New York State Department of Taxation and Finance has been providing “general guidance” -- answers to frequently asked questions (FAQs) -- on topics of interest to taxpayers. Recently, the Tax Department clarified two administrative issues with combined filing under the new regime and issued an FAQ with respect to the proper completion of the apportionment schedule on the return.

2016-17 New York State Budget

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NYSOn April 13, 2016, Governor Andrew M. Cuomo signed the 2016-17 New York State Budget into law. We summarize the highlights of the revenue provisions below.

Economic Nexus Extended Too Far – Hodgson Russ LLP v. Minnesota Department of Revenue

During the spring of 2014, Hodgson Russ LLP (“Hodgson”) received a letter from the Minnesota Department of Revenue (“Minnesota Revenue”) that attempted to establish a new low in the states’ “race to the bottom” to establish the most minimal constitutional standard required to satisfy substantial nexus with an out-of-state taxpayer.  Minnesota Revenue asserted that under suspect provisions of the Minnesota tax code, Hodgson had nexus with the state of Minnesota based upon a single, un-audited fact: between the 2004 and 2012 tax years, Hodgson received federal Forms 1099 from payors using a Minnesota mailing address.  On account of this single fact – with no revenue floor or other safeguards – Minnesota Revenue asserted that Hodgson had nexus with Minnesota, and was therefore required to file Minnesota franchise tax returns and apportion its business income to the state.

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