Alston & Bird Tax Blog

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.

About 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.

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About Josh Labat

Joshua A. Labat is an associate based in the New York office. Josh focuses his practice on complex state and local tax controversy, administrative proceedings, audits, litigation, and unclaimed property matters.

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