New York State Proposes to Tax Carried Interest Earned by Non-resident Partners
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The 2009 New York State budget proposed by Governor David Patterson yesterday contains a provision that would, effective January 1, 2009, impose New York tax on carried interest income allocated to non-residents of New York. It appears that the bill would require that (i) investment management services performed by a partnership or other entity in New York be treated as a business carried on in New York, and (ii) individual partners treat as New York source income their shares of carried interest for investment management services performed in New York.

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