No Secrets Are Safe In An Era Of Global Tax Information Exchange

Many taxpayers are familiar with information document requests where taxpayers are notified that taxing authorities are inquiring into certain transactions based on their receipt of the request. But today, many types of foreign tax information exchanges occur without the taxpayer’s knowledge. Moreover, tax administrations around the world are expanding tax information exchange programs. For example, on May 19, 2021, the European Union (“EU”) approved a measure to spend an additional € 270 million to […]

By | August 9th, 2021 ||

2021 Connecticut Tax Developments

Connecticut adopted a $46.4 billion budget for the two-year period that commenced July 1, 2021, reflecting a 2.6% spending increase for the first year and a 3.9% spending increase for the second year.There is much to love and hate about the budget regardless of your political persuasion, leaving many to wonder whether the state missed the opportunity to make more significant structural changes at a time when its economy is rebounding and its rainy […]

By | August 6th, 2021 ||

Nonresident Corporate Partner Subject To NYC Tax On Sale Of Partnership Interest

In Matter of Goldman Sachs Petershill Fund Offshore Holdings (Delaware) Corp., the New York City Tax Tribunal held that an upper-tier partnership’s passive corporate partner was subject to the New York City General Corporation Tax (GCT) on the upper-tier partnership’s sale of an interest in a lower-tier partnership that was doing business in New York City.

The GCT is imposed on the corporate partners of a partnership doing business in New York City. The administrative law […]

By | August 4th, 2021 ||