New York’s Unconstitutional Tax Residence Rule
CO-AUTHORS Michael S. Knoll
PUBLISHER
State Tax Notes
DATE
2017
UVA Law Faculty Affiliations
Abstract
In 1998 New York’s highest court upheld a dormant commerce clause challenge to the state’s statutory tax residence rule in Tamagni. This article argues that that case is no longer good law in light of the Supreme Court’s 2015 decision in Wynne because it is internally inconsistent and economically equivalent to a tariff.
Citation
Michael S. Knoll & Ruth Mason, New York’s Unconstitutional Tax Residence Rule, 85 State Tax Notes 707-716 (2017).
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