State Tax

State Taxation of Compensation and Benefits (Portfolio 1750)

  • This Portfolio focuses on the impact of state taxation on executive and employee compensation.


The Bloomberg Tax Portfolio, State Taxation of Compensation and Benefits discusses how a state’s ability to assert jurisdiction to tax individuals who earn money in connection with the performance of services is based on the individual’s domicile or residence in the state, or because the individual, although a nonresident, has earned money in the state through the performance of services attributed to the state.

Readers will gain a better understanding of the federal law that prohibits any state from imposing an income tax on “any retirement income” of an individual who is not a “resident” or “domiciliary” of the taxing state, as the determination of an individual’s residence or domicile for this purpose is made in accordance with the laws of the taxing state.

Table of Contents

1750.01. Background
1750.02. The State Income Tax Base – Conformity to Federal Base
1750.03. Residence or Domicile
1750.04. State Law Considerations in Securing Deferred Compensation
1750.05. Source Taxation of Nonresidents
1750.06. Source Issues With Respect To Other Compensatory Payments to Nonresidents
1750.07. Withholding and Special Accruals
1750.08. Congressional Action under the Commerce Clause
1750.09. Interests in Limited Liability Companies and Partnerships
1750.10. Constitutional Issues Relating to State Taxation
1750.11. Collection of Tax

Jimmy Gatliff
Jimmy Gatliff
Ernst & Young LLP
Richard Reichler
Meltzer, Lippe, Goldstein & Breitst LLP
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