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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 and multistate tax law. Noonan's Notes Blog is a winner of CreditDonkey's Best Tax Blogs Award 2017.
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Showing 24 posts by K. Craig Reilly.
Breaking Up Is Hard to Do: New York Report on High-Income Nonresidents in the New York Economy
Breaking up is hard to do. Or so the old Neil Sedaka song goes. And a new report from the New York City Comptroller’s Office suggests that when it comes to the love affair between New York City and the country’s highest-income earners, the song rings true.
Beyond the Clouds: Important Sales Tax Considerations for Web-Hosting Providers and Co-Location Facilities
Most people’s understanding of the Internet extends about as far as their eyes can see. In other words, they know that if they type a few words into the little white box beneath the colorful Google logo, within a fraction of seconds, hundreds of thousands of (hopefully) helpful results will appear on the screen. And that’s awesome. But few people, myself included, fully understand what takes place beyond the keyboards, screens, and cords. In fact, many people are likely willfully blind to the back-end operations of the Internet.
Out-of-State Attorney Not Subject to New York State Income Tax
https://www.hodgsonruss.com/practices-State_Local_Tax.htmlWe have all heard the jokes. “How many lawyers does it take to screw in a light bulb?” “Why won’t sharks attack lawyers?” “What’s the difference between an accountant and a lawyer?” Or, “How many lawyer jokes are there?” Well, actually, the last one’s easy. Only three. The rest are true stories.
But despite the general public’s lampooning of attorneys, New York State taxpayers might have found a lawyer they can celebrate (in addition, of course, to their friends at Hodgson Russ). Meet Patrick J. Carr, a retired New York State attorney living in Florida. Last month, a state administrative law judge (ALJ) ruled that Mr. Carr did not have to pay a $68,000 tax bill for services rendered in Florida. Mr. Carr was a member of the New York and New Jersey state bars and was admitted pro hac vice in Florida (for non-lawyer readers, “pro hac vice” is a fancy Latin way of saying that an attorney who has not been admitted to practice in a certain jurisdiction is permitted to help litigate a particular case in that state). And although Mr. Carr did not perform any services or maintain any office in the state, New York attempted to tax his income solely because of his New York law license. Are you starting to root for Mr. Carr? Thankfully, however, ALJ Barbara Russo dismissed the state’s position and announced that “merely holding a license to practice in New York is not the equivalent of carrying on a profession in New York state.” So why did New York think that it had the right to tax Mr. Carr?
Revised Property Transfer Tax Return Form Requests Additional Information About Hidden Buyers of New York City Real Estate
In February, the New York Times published an 8,000-word investigation into wealthy foreigners buying New York City real estate and taking advantage of U.S. laws that allow them to set up shell companies in order to obscure their true identities. The article, entitled “Towers of Secrecy,” points to Russian mobsters, corrupt Colombian politicians, and polluting Indian mining magnates. This type of publicity doesn’t mean that every person who uses an LLC to purchase or sell a New York City apartment is an apparent Bond villain. But the Times piece does underscore a recent enhanced focus on LLCs’ role in New York City real estate, and anyone considering using an LLC to transfer property in the city should take special note of a recent change to the city’s recording procedures.