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Michael Tedesco

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Yet Another State Effort to Narrow Public Law 86‑272 Heads to Court

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States are continuing to try to limit the scope of Public Law 86‑272 (“P.L. 86-272”), and a recently filed Wisconsin case highlights this trend. On January 28, 2026, Crutchfield Corporation and Crutchfield New Media, LLC (collectively, “Crutchfield Companies”) filed a declaratory judgment action in the Wisconsin Circuit Court for Dane County against the Wisconsin Department of Revenue, the Secretary of Revenue, and the Wisconsin Attorney General, challenging a Wisconsin administrative regulation that interprets P.L. 86‑272.…

A Decade After Tax Reform, New York City Proposes New Business Corporation Tax Regulations

By , , , and 7 Mins Read

The New York City (“City”) Department of Finance (“DOF”) has taken a significant step forward in implementing its corporate tax reform provisions enacted in 2015 by proposing the first installment of its regulations under a new Chapter 11A of Title 19 of the Rules of the City of New York (“Proposed Rules”). These Proposed Rules come nearly two years after the New York State (“State”) Department of Taxation and Finance (“DTF”) adopted its final regulations…

Rhode Island Enters the Fray, Proposes Second in the Nation Digital Advertising Tax

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On February 6, 2025, Rhode Island lawmakers heard testimony about Rhode Island Governor Daniel McKee’s proposed Digital Advertising Gross Revenue Tax (“RI Ad Tax”).  If enacted, the RI Ad Tax, which is included in Governor McKee’s proposed 2026 budget released last month (HB 5076), would be the second of its kind in the U.S. after Maryland’s digital advertising tax.  Maryland’s digital advertising tax has been embroiled in litigation since its enactment and we expect the…

Plot Twist: New York Legislation Would Give the Commissioner of Taxation and Finance Appeal Rights Following Certain Adverse Tribunal Decisions

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As part of the New York Budget Legislation (“S.B. 4009 / A.B. 3009”),  the Commissioner of the New York State Department of Taxation and Finance (“Commissioner”) will be given the right to appeal certain types of decisions from the New York State Tax Appeals Tribunal (“Tribunal”).  Currently, only taxpayers have the right to appeal Tribunal decisions.  This provision is on the cusp of becoming law after clearing both legislative chambers on May 1, 2023.  As…

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