There has been an inflection point in the economy as a result of work life returning to a new post-pandemic normal, including: hybrid work schedules for employees, employers downsizing office space, the "convenience of the employer" rule recently adopted in New Jersey and Connecticut, and the Millionaire's Tax enacted in New York, New Jersey and Massachusetts.

These changes are, in turn, impacting employees' choice of work arrangements and residency, domicile for trust and estate planning purposes, and employers' corporate income allocation. This article explores the far-flung tax consequences of post-pandemic recovery.

Convenience of the Employer Rule

New York State has for a long time employed the "convenience of the employer" rule to tax income of employees living out of state but working for a New York office. A question arose, even before the pandemic era of widespread work from home, whether New York considers compensation allocable to telecommuting, i.e. work from home, to be New York source income.