New York state income tax audit Q&A

>days in or out of New York always count as New
If you’re a salaried employee and performYork days.
any work in New York state you are subject to NewIf I’m not domiciled in New York and not a
York state income tax. Executives and other highlystatutory resident, can New York state still tax me?
compensated individuals are common targets forYes. New York can and will tax you on your New
audit. The following addresses common questions byYork source income. If you earn salary or wages,
salaried employees.your New York source income is the portion of your
If you move in or out of New York state inearnings from days spent in New York state.
conjunction with the sale of a business or a contractHow will the state prove I was in New York?
to end employment, you should consult with a taxThey won’t. The examiners will rely on you to
attorney. These issues are beyond the scope of thisprove you weren’t in New York. Each day
Q&A.you can’t prove that you spent the entire
Common New York income tax audit Q&A forday outside of New York will count as a day in New
salaried employees:York.
Why is New York state auditing me?How do I prove I wasn’t in New York?
New York state guards its income tax base byIf you do any work in New York state but are not a
conducting audits that can find either residency orresident, you need to maintain 1) a contemporaneous
New York source income. Residents of New Yorkcalendar that records your location on every day of
are liable for tax on their worldwide income.the year, 2) travel records, including tickets and
Non-residents are liable for tax on their New Yorkitineraries that establish the times you entered and
source income. Typical targets for audit areexited the state. The calendar you rely on needs to
executives and other high income earners that travelbe maintained in the regular course of your trade or
to New York state and file non-resident returns, orbusiness. If you assemble it in preparation for an
fail to file any return.examination, it’s too late— the
How could I be found resident of New York?examiners will not have to accept it, and probably
Two ways.won’t accept it.
First you may be domiciled in New York state andCan I avoid New York source income by working at
spend at least 30 days in the state during the year.home outside of New York?
Domicile is a legal concept that refers roughly toProbably not. If your employer is based in New York,
where you’re from. You can change yourworking at home, even if it is outside New York
domicile, but only if you move somewhere that is notstate, will still count as New York income unless your
temporary.employer requires you to work at home on that day.
Second, you may be a statutory resident of NewFor more about New York state’s position on
York. You are a statutory resident if you maintain athe source of income when you work from a home
home in New York (including an apartment you rent)office, see TSB-M-065(5)I . Do not confuse the
and spend more than 183 days in the state. With“convenience of the employer” test discussed
narrow exceptions, any portion of a day spent in thethere with the source rules discussed above that
state (even a minute) counts as a whole day. Travelapply when you are not working in your home.