Wynne, Cloud Computing, and a State’s Deference to Another


Arthur Rosen wrote in this bylined article that the Supreme Court’s Wynne decision could affect New York’s residency statute, which is similar to the Maryland county income tax at issue in Wynne. “New York state taxpayers should be cognizant of the Wynne decision and should consider filing refund claims if they have paid – or will pay – tax to New York state as a statutory resident (that is, not as a New York domiciliary),” Mr. Rosen wrote, adding his belief that the state’s tax authority would be “quite resistant to granting such refunds.”