New York is known for aggressively auditing nonresident tax returns in order to prove residency, according to partner Craig B. Fields in the Institutional Investor article “Financiers are gravitating to low-tax locales. Now authorities are fighting back.”
“New York state often will not hesitate to challenge a tax return reporting a high-net-worth individual’s change of domicile where certain factors are present — for example, where the individual continues to maintain a residence in New York or continues to spend a significant amount of time in New York,” he said.
Mr. Fields successfully argued in 2017 that former Colgate-Palmolive CFO Stephen Patrick was no longer a New York tax resident despite spending more than half of the year there.