- Challenged New Jersey’s alternative minimum tax on Supremacy Clause grounds.
- Challenged Illinois’s denial of sales tax bad debt refunds in federal court litigation.
- Litigated and resolved states’ economic nexus assertions nationwide, including submission of briefs as amicus curiae in Quill and Wayfair.
- Challenged New Jersey’s inclusion in taxable income of non-effectively connected income.
- Litigated the taxability of advertising services for New York state sales tax purposes.
- Advising parties in M&A transactions and significant restructurings.
- Represented taxpayers in nontraditional tax matters, including the New York City unincorporated business and commercial rent taxes, city of Chicago’s lease tax, Illinois franchise tax, and Florida documentary stamp tax.
Counsel,
- Phone: +1 212 210 9413
- Email: amy.nogid@alston.com
Amy’s clients in all industries know they have a champion when approaching multistate tax planning, restructurings, audits, or controversy. She has experience with the traditional and emerging tax issues businesses face, including economic nexus, add backs, apportionment, business/nonbusiness and unitary business determinations, and entity classification.
Amy Nogid is counsel in the State & Local Tax Group. She represents clients in all stages of state and local tax work from multistate tax planning and restructuring through audit to resolution via settlement or litigation.
Amy has litigated seminal SALT cases nationwide, including before the U.S. Supreme Court. Amy also advises industry-leading clients across the country in unclaimed property matters. With more than 35 years of experience, Amy partners with clients, ranging from startups to Fortune 500 companies, to represent them in a broad range of transaction-based taxes, including income, franchise, sales and use, and excise.
She’s a frequent contributor to publications on tax and unclaimed property matters and regularly presents at state and local tax conferences, including those sponsored by the Council on State Taxation, Tax Executives Institute, and Institute for Professionals in Taxation. Before joining private practice, Amy served as an assistant chief in the Tax and Bankruptcy Litigation Division of the New York City Law Department, litigating numerous tax cases on behalf of New York City’s Department of Finance. She also spent several years in public accounting.
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In the News May 22, 2024Law360 | NYC’s Proposed Split from State Tax Regs Sparks PushbackAmy Nogid is quoted on New York City’s plan to use the unincorporated business tax sourcing rule in its corporate tax regulations.In the News May 22, 2024Law360 | NYC’s Proposed Split from State Tax Regs Sparks PushbackAmy Nogid is quoted on New York City’s plan to use the unincorporated business tax sourcing rule in its corporate tax regulations.
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Speaking Engagement August 22, 2023Mid-Atlantic Regional State Tax SeminarMatt Hedstrom, Amy Nogid, and Zach Gladney will speak at this seminar hosted by the Council on State Taxation.Speaking Engagement August 22, 2023Mid-Atlantic Regional State Tax SeminarMatt Hedstrom, Amy Nogid, and Zach Gladney will speak at this seminar hosted by the Council on State Taxation.
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In the News June 16, 2023Law360 Tax Authority | Wayfair at 5: 5 Things We Know and 5 Things We Don’tAmy Nogid is quoted on state tax issues addressed by the U.S. Supreme Court’s Wayfair decision.In the News June 16, 2023Law360 Tax Authority | Wayfair at 5: 5 Things We Know and 5 Things We Don’tAmy Nogid is quoted on state tax issues addressed by the U.S. Supreme Court’s Wayfair decision.
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Speaking Engagement April 24 - 27, 2023COST 2023 Income Tax Conference & Spring Audit SessionAmy Nogid will be speaking at the 2023 Income Tax Conference & Spring Audit Session sponsored by the Council on State Taxation (COST).Speaking Engagement April 24 - 27, 2023COST 2023 Income Tax Conference & Spring Audit SessionAmy Nogid will be speaking at the 2023 Income Tax Conference & Spring Audit Session sponsored by the Council on State Taxation (COST).
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Advisories February 21, 2023State & Local Tax Advisory: Foreign Businesses Meet the Wild, Wild World of SALT — Part 2As first seen in State Tax Notes and Tax Notes International, Amy Nogid of our State & Local Tax Team continues her discussion of SALT issues for foreign businesses operating in the United States, addressing worldwide combination, extraterritorial income, and apportionment, as well as potential restraints on the ability to collect tax judgments from non-U.S. entities.Advisories February 21, 2023State & Local Tax Advisory: Foreign Businesses Meet the Wild, Wild World of SALT — Part 2As first seen in State Tax Notes and Tax Notes International, Amy Nogid of our State & Local Tax Team continues her discussion of SALT issues for foreign businesses operating in the United States, addressing worldwide combination, extraterritorial income, and apportionment, as well as potential restraints on the ability to collect tax judgments from non-U.S. entities.
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Advisories February 6, 2023State & Local Tax Advisory: Foreign Businesses Meet the Wild, Wild World of SALT – Part 1As first seen in State Tax Notes and Tax Notes International, Amy Nogid of our State & Local Tax Team discusses some of the rules to which non-U.S. businesses must abide, federal constitutional provisions that apply to non-U.S. businesses, threshold taxability issues, and quirky local taxes that routinely fall under the radar of foreign businesses.Advisories February 6, 2023State & Local Tax Advisory: Foreign Businesses Meet the Wild, Wild World of SALT – Part 1As first seen in State Tax Notes and Tax Notes International, Amy Nogid of our State & Local Tax Team discusses some of the rules to which non-U.S. businesses must abide, federal constitutional provisions that apply to non-U.S. businesses, threshold taxability issues, and quirky local taxes that routinely fall under the radar of foreign businesses.
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In the News January 6, 2023Law360 | Cookie Nexus Ruling Fuels Debate over MTC Income Tax RuleAmy Nogid is quoted on the state tax implications of the recent Massachusetts Supreme Judicial Court’s ruling finding that internet cookies don’t establish nexus.In the News January 6, 2023Law360 | Cookie Nexus Ruling Fuels Debate over MTC Income Tax RuleAmy Nogid is quoted on the state tax implications of the recent Massachusetts Supreme Judicial Court’s ruling finding that internet cookies don’t establish nexus.
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General Publications October 31, 2022“Justices Poised to Reject Narrowing Unclaimed Property Law,” Law360, October 31, 2022.Unclaimed property took center stage on the first day of the U.S. Supreme Court term when the court heard the long-awaited oral arguments in the consolidated cases of Delaware v. Pennsylvania and Wisconsin and Arkansas v. Delaware — commonly referred to as the MoneyGram case. This article discusses why the U.S. Supreme Court’s oral arguments in the bellwether MoneyGram unclaimed property case will likely lead to them deciding for the petitioners.General Publications October 31, 2022“Justices Poised to Reject Narrowing Unclaimed Property Law,” Law360, October 31, 2022.Unclaimed property took center stage on the first day of the U.S. Supreme Court term when the court heard the long-awaited oral arguments in the consolidated cases of Delaware v. Pennsylvania and Wisconsin and Arkansas v. Delaware — commonly referred to as the MoneyGram case. This article discusses why the U.S. Supreme Court’s oral arguments in the bellwether MoneyGram unclaimed property case will likely lead to them deciding for the petitioners.
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Speaking Engagement October 23-26, 202277th TEI Annual ConferenceAmy Nogid will present “The Worst SALT Decisions of the Year” at this conference hosted by the Tax Executives Institute (TEI).Speaking Engagement October 23-26, 202277th TEI Annual ConferenceAmy Nogid will present “The Worst SALT Decisions of the Year” at this conference hosted by the Tax Executives Institute (TEI).
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Webinar February 11, 2022Charlotte SALT Ladies’ RoundtableJoin us as we discuss recent judicial, legislative, and administrative SALT developments and professional issues of particular interest to women.Webinar February 11, 2022Charlotte SALT Ladies’ RoundtableJoin us as we discuss recent judicial, legislative, and administrative SALT developments and professional issues of particular interest to women.
Bar Admissions
- New York
- U.S. Supreme Court
Education
- New York University (LL.M., 1989)
- New York University (J.D., 1982)
- Queens College (B.A., 1976)
Memberships
- State Tax Notes Advisory Board
- New York City Bar Association, State & Local Taxation Committee, chair
- Income Tax Committee, IPT 2015 Annual Conference, co-chair
- New York City Tax Appeals Tribunal, Rules Advisory Committee
- New York State Bar Association, New York State Taxes Committee
- University of Wisconsin-Milwaukee, Lubar School of Business, State & Local Tax Lecture Series, advisory board
Court Admission
- U.S. Tax Court
- U.S. Court of Appeals for the Second Circuit
Accolades
- The Legal 500 United States (U.S. Taxes: Non-Contentious, 2016)
- Municipal Affairs Committee of the New York State Bar Association, Excellence in Public Service Law