Working Remotely: Where Are Wages Sourced?

States have different rules for determining where wages earned by a remote worker are sourced: to the worker’s location or the company’s location. New Your uses a “convenience of the employer” rule, which makes wages sourced to the company’s location unless working remotely for the necessity of the employer. In a recent tax appeals tribunal decision, a New York law school professor required to work from his home in Connecticut during COVID because he couldn’t get to his New York office argued he should not be subject to New York taxes on his wages. The tribunal ruled otherwise. Even though he spent less than 10% of his total work days within New York, this was enough to say he “availed himself of the benefits of the economic market in New York through his employment.” #IdeaoftheDay

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