In an earlier column, we addressed the New York State Department of Taxation and Finance’s (the “Department”) aggressive nonresident audit program and the unique challenges that arise when a taxpayer’s change of residency is followed by a transaction in which he or she recognizes a large capital gain. (Defending New York Residency Audits that Target Capital Gain). In this column, we address another type of audit where the Department has demonstrated a propensity for aggressively pursuing full resident taxation. These audits involve individuals who have claimed a change of domicile to a foreign country.

Read more at Tax Stringer.