The State of NY Tax

Last week, New York’s Governor Cuomo released his proposed budget for the State’s 2021 fiscal year. After criticizing the Federal limitation on itemized deductions for state and local taxes,[i] the Governor commented on the “out-migration” from the State of many high-earning New Yorkers, thus implying a causal connection between

Last week’s post explored the federal income tax consequences to a taxpayer who failed to timely file an election for the classification of his wholly-owned business entity.

Today’s post considers how one taxpayer sought to utilize the IRS’s business entity classification rules to reduce his estate’s exposure for NY estate tax. Individuals who are not