Document Type
Article
Publication Date
1-15-2018
Abstract
In this article, we respond to Professor Zelinsky’s criticism of our arguments regarding the constitutionality of New York’s tax residence rule. We argue that the Supreme Court’s decision in Wynne requires reconsideration of the New York Court of Appeal’s decision in Tamagni.
Keywords
Constitutional law, state income taxation, dormant commerce clause, Comptroller of the Treasury v. Wynne, internal consistency test, subsidies, residence rules, double taxation, discriminatory taxation
Publication Title
State Tax Notes
Repository Citation
Knoll, Michael S. and Mason, Ruth, "Dual Residents: A Sur-Reply to Zelinsky" (2018). All Faculty Scholarship. 1961.
https://scholarship.law.upenn.edu/faculty_scholarship/1961
Included in
Economic Policy Commons, Law and Economics Commons, Policy Design, Analysis, and Evaluation Commons, Public Economics Commons, Taxation Commons, Taxation-Federal Commons, Taxation-State and Local Commons
Publication Citation
State Tax Notes, January 15, 2018, p. 269