Unforgettable learning experiences!
This 60-minute interactive CLE operates as a continuous residency-audit simulation. Each table acts as an audit team, with participants serving as taxpayer counsel, client/record keeper, Department auditor, reviewer, and observer. Using the hypothetical Morgan Reed case, an executive who moves from Manhattan to Greenwich before an $18 million liquidity event, participants take an initial position and reassess it as legal standards and staged exhibits are introduced.
Participants apply domicile, statutory-residency, permanent-place-of-abode, day-count, and wage-sourcing rules through opening statements, exhibit ranking, a disputed-day calculation, a Holt-based ledger cross-examination, and an employer interview. The exercises address New York's convenience rule, Zelinsky, assigned-office and bona fide office tests, compensation allocation, COVID-era moves, a $60 million sale, and New Jersey and Connecticut comparisons. The session concludes with a tri-state rapid fire and audit closing conference.
- Distinguish domiciliary residency from statutory residency.
- Apply the five New York primary domicile factors and evaluate abode access, day counts, exclusions, and governing factual assumptions.
- Rank documentary proof and identify contradictions, credibility defects, and missing exhibits in an audit file.
- Analyze remote-work and compensation sourcing under convenience, assigned-office, employer-necessity, and bona fide office rules.
- Compare tri-state rules and advocate a defensible issue-by-issue position during an audit closing conference.
Talented, Professional Team
Michael Y. Goldberg, Esq.
MANAGING ATTORNEY | GOLDBERG TAX LAW
Michael Goldberg as an LLM, CPA, CVA is the managing attorney of Goldberg Tax Law, LLC a national tax litigation and controversy firm, focusing on federal and state controversy matters for individuals and businesses. Super Lawyers magazine has named Mike as a Rising Star in Maryland, Washington, DC and New York from 2017 through 2025 and he has been recognized by Best Lawyers magazine as a One to Watch from 2021 through 2025...
Avi Kafka, Esq.
ATTORNEY | GOLDBERG TAX LAW
Avi Kafka is an associate tax law attorney of Goldberg Tax Law, LLC a national tax litigation and controversy firm, focusing on federal and state controversy matters for individuals and businesses. Avi represents clients with a wide range of tax issues, from negotiating with the IRS to solving corporate structure issues to complex cryptocurrency tracking and compliance...
I simply want to applaud you both for such stellar and entertaining
performances in the mock ethics scenarios. The diversity of situations
presented was truly eyebrow-raising and memorable. The discussion format
was also quite entertaining and digestible. Overall, a great CLE.
Very good course, instructor and materials. I took another course with
this instructor and she comes across as very knowledgeable and
experienced. She enlivens the course with numerous anecdotes and
examples from cases she has handled.
I found the way the material was presented made it interesting but also
was effective in modeling how to analyze and discuss these issues with a
colleague. This was the most interesting CLE that I’ve ever taken. Kudos to the presenters!
