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

April 9, 2020 By Zach Gladney and Josh Labat

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.

Filed Under: State & Local Tax Tagged With: broker-dealer, New York, SMLLC, tribunal

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.

[Read Bio]

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.

[Read Bio]

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