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.
Constitutional law, state income taxation, dormant commerce clause, Comptroller of the Treasury v. Wynne, internal consistency test, subsidies, residence rules, double taxation, discriminatory taxation
State Tax Notes
Knoll, Michael S. and Mason, Ruth, "Dual Residents: A Sur-Reply to Zelinsky" (2018). Faculty Scholarship at Penn Carey Law. 1961.
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State Tax Notes, January 15, 2018, p. 269