Dual Residents: A Sur-Reply to Zelinsky
7 Pages Posted: 14 Feb 2018 Last revised: 20 Feb 2018
Date Written: January 15, 2018
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
JEL Classification: H20, H71, K34
Suggested Citation: Suggested Citation