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Articles Posted in New York

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Five Things You Should Know About New York State’s Taxation of Convertible Virtual Currency

On December 5, 2014, the New York State Department of Taxation and Finance issued TSB-M-14(5)C, (7)I, (17)S, explaining its policy regarding convertible virtual currency. The IRS has held that convertible virtual currency (CVC), such as bitcoin, is treated as property for U.S. federal income tax purposes. Consequently, transactions involving CVC…

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Heads They Win, Tails You Lose: New York Decombination and Discretionary Adjustments

A New York state corporate franchise tax audit is almost as frustrating as participating in a coin toss with a one-sided coin. It seems like taxpayers cannot win. New York state auditors forcibly combine taxpayers that have filed separate returns and decombine taxpayers that have filed combined returns. Auditors also…

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The Deliberative Process Privilege in State Controversy Matters

Taxpayers involved in state tax controversy matters often request information and documentation from state tax authorities to analyze audit adjustments. Some of those requests are thwarted by state tax authorities’ assertions of the deliberative process privilege to prevent the disclosure of information or documentation that may compromise the state tax…