Author Archives: Zach Gladney

Zach Gladney
Zach Gladney is a partner in the firm’s State & Local Tax Group, concentrating his practice on complex state tax controversy in jurisdictions across the country and sophisticated corporate restructurings.  Read More →

NY Tribunal Disallows Broker-Dealer Sourcing for Receipts from a Disregarded LLC

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Our State & Local Tax Team discusses a decision from the New York Tax Appeals Tribunal that holds that a single member of a broker-dealer is not entitled to use broker-dealer sourcing in NY. Decision impacts millions at stake for NY taxpayers Taxpayers relied on prior guidance from the NY Division of Taxation The Tribunal reverses a widespread view on disregarded LLCs Read the full advisory here. [...]Read more

Amendment to NYS Tax Law Affects Recording of Deeds for LLCs

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New York’s new real estate transfer tax recording requirements for LLCs raise questions on whether the scope and complexity of the changes can be enforced or noncompliance monitored. Our State & Local Tax Group explores: Disclosing all LLC members Who is a “natural person”? Compliance and confidentiality concerns Read the full advisory here. [...]Read more

U.S. Supreme Court Carves a Narrow Taxpayer Win on Due Process in Kaestner

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One year after dropping the landmark Wayfair decision, our State & Local Tax Group examines why this year’s Supreme Court decision in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust won’t leave much of a mark. Kaestner focuses narrowly on the trust at issue in the case The Court goes out of its way to ensure that the decision does not affect precedent The decision reaffirms the due-process test of Quill Read the full advisory here. [...]Read more

State Guidance Needed After Treasury Issues Proposed Regulations Under Section 163(j)

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Our State & Local Tax Group examines why proposed federal regulations for the new interest expense limitation complicates matters for state tax purposes. Not every state follows the new Section 163(j) Federal deduction determined on a consolidated basis … … But states are all over the place Read the full advisory here. [...]Read more

Garden State Tax Amnesty in Full Bloom for Two Months

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New Jersey’s tax amnesty program might make the holiday season a little brighter for some taxpayers. Our State & Local Tax Group explains the program’s ins and outs and why the time to act is now for those seeking to take advantage of the program’s limited one-time offer. Effective November 15 – January 15 Waives penalties and cuts interest payments for qualifying taxpayers Does not offer taxpayer anonymity or lookback protection for historic liabilities Read the full advisory here. [...]Read more

‘Wayfair’: What Are the Practical Retroactivity Concerns?

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What is the practical risk that states attempt to apply Wayfair retroactively? And should taxpayers rush to limit exposure for historical periods by entering into voluntary disclosure agreements with states that might assess tax retroactively under Wayfair? In an article originally published in Bloomberg BNA’s Weekly State Tax Report, Zach Gladney and Charles Wakefield explain why applying Wayfair retroactively would be misguided and unsuccessful. To read the full article, click here. [...]Read more