Overemployed Across State Lines: The Tax Problem Nobody Warns You About

The overemployed arrangement is simple to describe. You hold two or more full-time remote W-2 jobs at the same time, neither employer knows about the other, and you work all of them from the same desk in the same house. The federal side of this is boring: two W-2s, one Form 1040, one set of brackets, and a withholding calculation that comes up short because each employer withheld as though it were your only job. Annoying, solvable, well documented in a hundred places.

The state side is where the arrangement quietly breaks, and almost nothing written for the overemployed community covers it. Most people carry one assumption into a second job: that wages are taxed where the work is physically performed, and since all of the work happens in one house, only one state is involved. That assumption is correct in most of the country and wrong in the places where remote jobs actually cluster.

Six states apply a version of the convenience of the employer rule, which sources a nonresident employee’s wages to the employer’s state on days the employee worked at home, unless the employee can show the out-of-state work was required by the employer rather than chosen by the employee. The rule was designed for one telecommuter with one employer. Nobody drafted it with two simultaneous employers in mind, and it does not degrade gracefully when you add the second one. It just runs twice.

This article is informational and is not legal or tax advice. Multi-state wage sourcing turns on the specific facts of who employs you, where their office is, what they told you in writing, and where your body actually was. Work through your own situation with a qualified CPA or tax attorney before you file.

Start with the baseline, because you need it to see the exception clearly. Your state of residence taxes all of your income, from every source, wherever earned. A state where you are a nonresident taxes only the income sourced to it, and for wages the ordinary sourcing rule is physical presence: compensation is sourced to the state where you performed the services. Connecticut states the ordinary version plainly in its withholding guidance for nonresidents. "Wages of a nonresident employee are subject to Connecticut income tax withholding if the wages are paid for services rendered in Connecticut," and "Wages of a nonresident are not subject to Connecticut income tax withholding if the wages are paid for services performed entirely outside of Connecticut."

That is the rule the overemployed arrangement assumes. If it held everywhere, two remote jobs worked from a house in Austin would produce zero state tax, because Texas has no income tax and neither employer’s state could reach services performed in Texas.

New York’s regulation is where it stops holding. Under 20 NYCRR 132.18(a), a nonresident’s New York income is "that proportion of his total compensation for services rendered as an employee which the total number of working days employed within New York State bears to the total number of working days employed both within and without New York State." So far this is ordinary day-count apportionment. The next sentence is the whole problem: "any allowance claimed for days worked outside New York State must be based upon the performance of services which of necessity, as distinguished from convenience, obligate the employee to out-of-state duties in the service of his employer."

Read that carefully. It does not say your out-of-state days are New York days. It says you may only subtract them if you can show they were compelled by the employer’s necessity. Days you worked at home because working at home suited you are not subtracted. They stay in the New York numerator. The regulation also excludes nonworking days from the count entirely: "no account is taken of nonworking days, including Saturdays, Sundays, holidays, days of absence because of illness or personal injury, vacation, or leave with or without pay," which means the denominator is your working days, not your calendar.

The Tax Department states the practical consequence in its own nonresident guidance without hedging. "If you are a nonresident whose primary office is in New York State, your days telecommuting are considered days worked in the state unless your employer has established a bona fide employer office at your telecommuting location." And then, in case anyone hoped the bona fide office exception was easy: "In general, unless your employer specifically acted to establish a bona fide employer office at your telecommuting location, you will continue to owe New York State income tax on income earned while telecommuting." That exception is a multi-factor test, and a spare bedroom does not satisfy it. It is meant to describe an office the employer actually established, not a place the employee happens to sit.

Six states are worth knowing by name if you hold more than one remote job, because their rules differ in a way that changes your exposure depending on where you live.

New York’s rule is unconditional. It applies to any nonresident whose primary office is in New York, regardless of where the nonresident lives or what that state does. Delaware, Nebraska, and Pennsylvania run rules of the same general shape.

Connecticut’s rule is conditional and retaliatory. Conn. Gen. Stat. section 12-711(b)(2)(C), added by Public Act 18-49 and effective for tax years beginning January 1, 2019, reads: "For purposes of determining the compensation derived from or connected with sources within this state, a nonresident natural person shall include income from days worked outside this state for such person’s convenience if such person’s state of domicile uses a similar test." In practice Connecticut reaches wages paid to employees working outside the state only where the state they work from is Delaware, Nebraska, New York, or Pennsylvania, and only where the out-of-state work is for other than a bona fide reason of the employer.

New Jersey joined in 2023 with the same conditional design. P.L. 2023, c.125, enacted July 21, 2023, is retroactive to January 1, 2023, and the Division of Taxation describes the mechanism as mirroring: "New Jersey will apply another state’s Convenience of the Employer Rule on nonresidents, which would be the same as the one in the nonresident’s home state." Its current reach is residents of Delaware, Nebraska, and New York who work remotely for New Jersey employers. Pennsylvania residents are excluded by the long-standing Pennsylvania and New Jersey reciprocal agreement, and Connecticut employees are excluded, in the Division’s words, "based on the reciprocal nature of Connecticut’s law."

The asymmetry is the practical takeaway, and it cuts in a direction most people guess wrong. Living in a no-tax or no-convenience-rule state does not protect you from New York. It does protect you from Connecticut and New Jersey. A person working two remote jobs from Austin, one for a New York employer and one for a Connecticut employer, gets the worst of New York’s unconditional rule on the first job and none of Connecticut’s conditional rule on the second, because Texas does not use a similar test. Someone moving from California to Texas with a New York paycheck in hand has changed which state taxes their non-wage income and has changed nothing at all about the New York job.

Now run it the other way, which is the version that surprises people. You live in Brooklyn. Job A is with a New York employer. Job B is with a New Jersey employer, and you have never once been to its office. New Jersey now applies its convenience rule to you specifically because New York, your home state, has one. Job B’s wages get sourced to New Jersey. New York, meanwhile, taxes you as a resident on everything, both jobs, at a top state rate of 10.9% with New York City adding up to another 3.876%. New Jersey’s top rate is 10.75%. Whether that overlap costs you real money now depends entirely on a resident credit, which is a mechanism with edges. People who move the other direction, moving from New York to New Jersey, swap which of the two rules is the unconditional one and inherit New Jersey’s own convenience regime as residents.

Everything in the convenience rule turns on one distinction: did the employer require you to work outside the state, or did you choose to. Twenty years of litigation have made that distinction narrower than any reasonable person would guess, and the most recent chapter closed six weeks ago.

Edward Zelinsky is a law professor at the Benjamin N. Cardozo School of Law in Manhattan who lives in Connecticut. He taught on campus roughly three days a week and did the rest of his work at home. He challenged New York’s convenience rule and lost at the Court of Appeals in Zelinsky v. Tax Appeals Tribunal, 1 N.Y.3d 85 (2003). That is the case usually cited for the proposition that the rule survives constitutional attack.

He brought it again for tax years 2019 and 2020, and this time the facts looked unbeatable. Cardozo closed to in-person activity in March 2020 under an executive order that required non-essential workers to telework. He was not permitted on campus. He could not have taught from his New York office if he had wanted to. If employer necessity means anything, a locked building ought to be it.

He lost at every level. An administrative law judge sustained the rule on November 30, 2023, in DTA Nos. 830517 and 830681. The Tax Appeals Tribunal affirmed on May 15, 2025. And on July 2, 2026, the Appellate Division, Third Department, confirmed the Tribunal in Matter of Zelinsky v. Commissioner of Taxation and Finance, CV-25-1156.

The reasoning is the part to sit with, because it defines necessity for everyone else. The court accepted that the executive order barred Zelinsky from campus, but held that "it did not require Zelinsky to teach from Connecticut." The employer had no view on the matter. As the court put it, "the law school was indifferent to the state from which faculty delivered videoconference lectures or meetings." What explained his working from Connecticut was, in the court’s words, "a temporary but grave public health emergency, not ‘employer necessity.’" The operative line for the rest of us is the distinction the court drew between work that must be performed at a particular site for the employer’s need or benefit and work that could be performed anywhere. Work that could be performed anywhere, performed somewhere by the employee’s choice, is convenience.

On the constitutional arguments the court was equally short. On the dormant Commerce Clause it held that "nonresidents do not implicate themselves or their employers in interstate commerce merely by working from home," and on due process it found the required minimal connection between taxpayer and state satisfied by his continued receipt of the benefits of New York employment.

Now apply that standard to an overemployed arrangement, and notice what happens. Employer necessity is a fact about the employer’s requirement, not about the employee’s situation. It has to be established separately for each employer, because each employer is a separate sourcing question with a separate office in a separate state. Two jobs means two independent showings.

And the showing is one an overemployed worker is structurally unable to make. The entire premise of holding two undisclosed jobs is that neither employer has directed you to a specific out-of-state location for its own benefit. Each of them is, in the precise sense the Third Department used, indifferent. That indifference is not a gap in your documentation. It is the arrangement working as designed, and it is exactly what the rule treats as convenience.

If Zelinsky shows what necessity means, Huckaby shows what it costs, and it is the case to read before deciding this is a small exposure.

Thomas Huckaby lived in Tennessee and worked for the National Organization of Industrial Trade Unions, based in Jamaica, New York. For tax years 1994 and 1995 he worked in his employer’s New York office 56 days and 62 days respectively, roughly 25% of his working days. He and his employer had agreed he would work from Tennessee and travel to New York as needed. He allocated his income accordingly.

New York applied the convenience rule and taxed 100% of his compensation. The Court of Appeals affirmed on March 29, 2005, in a 5 to 2 decision, with Judge R.S. Smith dissenting, joined by Judges G.B. Smith and Ciparick. The majority quoted the same regulation this whole article turns on, that any allowance for out-of-state days "must be based upon the performance of services which of necessity, as distinguished from convenience, obligate the employee to out-of-state duties in the service of his employer," and found the due process minimal connection satisfied because, in its words, that connection "plainly exists in this case where petitioner accepted employment from a New York employer and worked in his employer’s New York office approximately 25% of the time annually."

Twenty-five percent of the days, one hundred percent of the wages. That is the ratio to keep in mind. The rule is not a proration and it is not a penalty for spending too many days somewhere. It removes the apportionment entirely.

Note also that Huckaby had traveled to New York. A person who never sets foot in the state has a different set of facts on the due process question, but the Tax Department’s published position does not carve them out, and Zelinsky establishes that a locked office is not necessity. Do not plan around the assumption that never visiting is a defense.

The usual reassurance is that a resident credit prevents double taxation: your home state credits you for tax you paid to the other state, so the money is only paid once at the higher of the two rates. That is broadly how the system is supposed to work, and for a single conventional job it usually does. Two things make it unreliable for the overemployed arrangement.

First, a resident credit is a credit for tax paid on income that the home state also agrees was sourced to the other state. When the other state claims income under a convenience rule, the two states are disagreeing about sourcing, not about rates. The credit sits on top of that disagreement rather than resolving it, and both legislatures know it. That is precisely why New Jersey and Connecticut wrote their own rules as mirrors instead of relying on credits to sort it out.

Second, the relief that does exist is narrow and conditional, and reading it closely tells you how the states themselves rate the odds. Connecticut’s H.B. No. 6516, signed March 4, 2021, allowed a Connecticut resident who paid tax to a state that uses a convenience rule to claim a credit against Connecticut income tax on remotely earned income. Connecticut’s own guidance then limited that relief to the 2020 tax year.

New Jersey went further, and the design is worth reading as a warning label. P.L. 2023, c.125 created a refundable Gross Income Tax credit for New Jersey residents who successfully challenge another state’s convenience rule. To qualify, a taxpayer must "Be a New Jersey resident," "Pay income tax or wage tax to another state," "Apply for and be denied a refund from the other state on income earned while working remotely (e.g., from home) in New Jersey," "File an appeal of the other state’s tax assessment in an out-of-state tax court or tribunal," "Obtain a final judgment in their favor from that tax court or tribunal," and "Receive a refund from the other state as a result." The judgment must satisfy the other state’s finality requirements. The credit covers tax years 2020 through 2023 and is worth "a credit of 50% of the additional tax that is owed to New Jersey," claimed by sending the favorable judgment and an amended NJ-1040 to the Division’s Gross Income Tax Audit Branch.

Look at what New Jersey is offering. Not a credit for being taxed twice. A partial credit for winning a contested case in another state’s tribunal first. Zelinsky spent six years and three levels of review doing exactly that and lost. Someone moving from New York to Connecticut or into New Jersey while keeping a New York paycheck is stepping into that same gap, which is a real cost of the corridor and not a rounding error.

Everything above concerns sourcing: which slice of which paycheck belongs to which state. There is a worse outcome, and overemployed workers walk into it more often than most people because two jobs generate two sets of onsites, two sets of travel obligations, and, very often, a place to sleep near one of them.

If a state decides you are its resident, sourcing stops mattering. It taxes your worldwide income, meaning both paychecks, the one from its own employers and the one from the employer three states away.

New York’s statutory residency test is the sharpest version. Under Tax Law section 605(b)(1)(B), a person not domiciled in New York is taxed as a resident on worldwide income if they maintain a permanent place of abode in New York for substantially all of the taxable year and spend more than 183 days of the year in New York. Both prongs must be met, and exactly 183 days does not trigger it. Since 2022 the Tax Department’s audit guidelines define substantially all of the taxable year as a period exceeding 10 months, down from 11. The day count is the trap: under 20 NYCRR 105.20, presence in New York for any part of a calendar day counts as a full day, with narrow exceptions for people in the state solely for medical treatment or solely passing through to somewhere else. A quarterly onsite week, plus a monthly team day, plus the trips you would take anyway, plus an apartment you kept because two salaries made it affordable, is a combination that reaches 184 without anyone deciding anything.

Connecticut runs the same two-prong structure under Conn. Gen. Stat. section 12-701(a)(1), permanent place of abode plus more than 183 days, with one meaningful difference: Connecticut’s regulations treat a genuinely temporary work-assignment apartment as not a permanent place of abode, a narrower carve-out than New York offers. New Jersey’s version, N.J.S.A. 54A:1-2(m), is also abode plus more than 183 days.

California is different in kind and worse in one specific way. Under Revenue and Taxation Code section 17014 there is no day-count threshold at all; a resident is anyone in the state for other than a temporary or transitory purpose. Section 17016 presumes residency for anyone present more than nine months of the taxable year, rebuttable only with evidence the presence was temporary or transitory, and there is no symmetrical safe harbor below nine months. The Franchise Tax Board has four years to assess a filed return, and under R&TC section 19057(a) there is no statute of limitations at all for a year in which no return was filed and the FTB believes you were a resident. ResidencyIQ’s dossiers rate California and New York 5 out of 5 on audit aggressiveness, Connecticut and New Jersey 4 out of 5.

The rates make the stakes concrete. California tops out at an effective 13.3%, New York at 10.9% with New York City adding up to 3.876% on top, New Jersey at 10.75%, Connecticut at 6.99%. Applied to two full salaries rather than one, a residency determination is not a marginal adjustment. The residency savings and exposure calculator runs the rate arithmetic against real bracket data alongside each state’s audit posture, which is the pairing that matters here: the savings and the exposure are the same decision.

The instinct with an undisclosed second job is to be quiet about it. That instinct works on your employers and does not work on revenue agencies, because the arrangement generates state-level reporting on its own and you are not the one filing it.

Two W-2s carry state wage and withholding boxes, and each employer files those with the state it thinks you work in. If Job A reports New York wages and Job B reports New Jersey wages, two states now hold a wage record for you, each of which contradicts any return that treats you as belonging entirely to a third state. Nothing about that requires an auditor to be clever.

The payroll state is its own problem. Employers commonly code withholding to the office location or to whatever address you gave HR, and an address given casually to a second employer for convenience becomes a sworn-adjacent data point about where you live. A W-2 naming a state you say you do not live in is one of the cheapest audit triggers there is.

And the reconstruction tools are ordinary. New Jersey’s Division of Taxation works residency cases from bank and brokerage statements, cell phone records, E-ZPass toll records, airline tickets, insurance policy riders tied to a New Jersey address, credit card statements, and comparison against prior years’ filing history. New York’s program is the most developed in the country, and a nonresident audit there commonly runs 12 to 24 months from first contact to resolution.

The worst available position is not an aggressive filing. It is no filing. New York’s three-year assessment window extends to six years where more than 25% of income is omitted from a return, and runs indefinitely where no return was filed at all. California is the same shape with a four-year window and no limit where nothing was filed. A second job creates filing obligations in states you may not have considered, and skipping those returns is what converts a defensible dispute about sourcing into an open-ended one.

The good news is that the record this requires is cheap to keep while the year is happening and impossible to reconstruct honestly two years later. The categories below are the ones that decide these cases.

Count days by state, not by employer. Every residency test that can reach your worldwide income counts days of physical presence in a jurisdiction, and it does not care which job you were doing that day or whether you were working at all. A day in New York for Job A’s onsite is the same day as a day in New York for anything else.

Keep a per-employer, per-day work location log. Sourcing is the separate question, and it is answered employer by employer. You need to be able to say, for each employer, how many working days you spent in that employer’s state and how many you spent outside it. Note that the denominator excludes weekends, holidays, illness, and vacation, so a log built on calendar days will produce the wrong fraction.

Capture employer directives in writing at the time they are given. This is the single highest-value item and the one nobody keeps. If an employer genuinely requires you to be somewhere outside its state for its own reasons, the necessity showing lives in an email, an offer letter clause, a written remote work agreement, or a policy document, and it has to name the requirement rather than merely permit the arrangement. Zelinsky lost because his employer was indifferent. Permission is not necessity, and an employer that would have been equally happy with any location has given you nothing to file.

Be honest about the second place to sleep. A pied-a-terre, a crash pad, a room you keep in a friend’s apartment near the office you visit quarterly: under most state definitions these are abodes, and the abode prong of a statutory residency test is usually the easy one for the state to prove. If you hold one in New York, New Jersey, or Connecticut, your entire protection is the day count, and a day count without records is not a defense.

Reconcile the state boxes on both W-2s before you file, not after. Compare what each employer reported to where you actually were, and fix the withholding coding going forward rather than filing around it.

Document the state you claim as home continuously. Driver’s license, voter registration, vehicle registration, a home you actually pay for and return to, local medical and financial relationships. This is the same evidence file a mover builds, and an overemployed worker needs it for the same reason: the claim is about where your life is, not where your paychecks originate.

The Mobility Map records days and nights across states as they happen, measured against each jurisdiction’s own day-count threshold, which is the number that decides whether a sourcing dispute stays a sourcing dispute or becomes a worldwide-income residency determination. Evidence Vault holds the records that answer the necessity question employer by employer: written remote work agreements, offer letters, employer directives, lease and abode documents, and the license and registration records that support a claimed home state. AuditIQ surfaces thin days and retained-tie exposure in the states you actually spend time in, including the employer state you fly into for onsites, and advisor sharing lets a CPA or tax attorney review the chronology and the underlying documents directly.

ResidencyIQ organizes records and highlights potential exposure factors. It is not a law firm or an accounting firm and does not provide legal or tax advice; work with a qualified CPA or tax attorney on your own domicile, filings, and state exposure.

N.Y. Comp. Codes R. & Regs. tit. 20, section 132.18(a) is the source of all three quoted passages: the allocation fraction based on working days within New York over working days within and without, the requirement that any allowance for out-of-state days rest on services which "of necessity, as distinguished from convenience," obligate the employee to out-of-state duties, and the exclusion of nonworking days including Saturdays, Sundays, holidays, illness, vacation, and leave: https://www.law.cornell.edu/regulations/new-york/20-NYCRR-132.18.

New York State Department of Taxation and Finance, "Frequently Asked Questions about Filing Requirements, Residency, and Telecommuting for New York State Personal Income Tax," is the source of the two quoted telecommuting statements about days telecommuting being days worked in the state absent a bona fide employer office, and of the statutory residency framing quoted in the residency section: https://www.tax.ny.gov/pit/file/nonresident-faqs.htm.

Matter of Zelinsky v. Commissioner of Taxation and Finance of the State of New York, CV-25-1156 (N.Y. App. Div. 3d Dept., July 2, 2026), is the source of the July 2, 2026 decision date, the 2019 and 2020 tax years, and the quoted holdings that the executive order "did not require Zelinsky to teach from Connecticut," that "the law school was indifferent to the state from which faculty delivered videoconference lectures or meetings," that the explanation was "a temporary but grave public health emergency, not ‘employer necessity,’" that "nonresidents do not implicate themselves or their employers in interstate commerce merely by working from home," and the must-be-performed versus could-be-performed distinction: https://www.currentfederaltaxdevelopments.com/blog/2026/7/2/the-persistence-of-new-yorks-convenience-of-the-employer-rule-in-the-pandemic-era and https://natlawreview.com/article/new-york-appellate-court-upholds-application-convenience-employer-rule-against and https://ogletree.com/insights-resources/blog-posts/new-york-professor-denied-tax-withholding-for-out-of-state-pandemic-remote-work/.

The procedural history below the Appellate Division, the administrative law judge determination of November 30, 2023 in DTA Nos. 830517 and 830681 and the Tax Appeals Tribunal decision of May 15, 2025 affirming it, together with the earlier Court of Appeals decision in Zelinsky v. Tax Appeals Tribunal, 1 N.Y.3d 85 (2003), come from Hodgson Russ’s Noonan’s Notes coverage of the Tribunal decision: https://www.hodgsonruss.com/Noonans-Notes-Blog/strike-two-in-zelinsky-ii-tax-appeals-tribunal-upholds-the-convenience-rule-again.

Matter of Huckaby v. New York State Division of Tax Appeals, Tax Appeals Tribunal (N.Y. Ct. App., March 29, 2005), is the source of the 1994 and 1995 tax years, the Tennessee residence and the National Organization of Industrial Trade Unions employer in Jamaica, New York, the 56 and 62 New York working days amounting to roughly 25%, the 5 to 2 vote with Judge R.S. Smith dissenting joined by Judges G.B. Smith and Ciparick, and the quoted due process holding that the minimal connection "plainly exists in this case where petitioner accepted employment from a New York employer and worked in his employer’s New York office approximately 25% of the time annually": https://www.law.cornell.edu/nyctap/I05_0051.htm.

Conn. Gen. Stat. section 12-711(b)(2)(C) is quoted in full from https://codes.findlaw.com/ct/title-12-taxation/ct-gen-st-sect-12-711/. Its enactment as Public Act 18-49 effective for tax years beginning January 1, 2019, and the description of Connecticut’s reach as covering employees performing services from Delaware, Nebraska, New York, or Pennsylvania for other than a bona fide reason of the employer, come from EY Tax News, "Connecticut law affects income tax and withholding on certain telecommuters": https://taxnews.ey.com/news/2018-1150-connecticut-law-affects-income-tax-and-withholding-on-certain-telecommuters. Connecticut H.B. No. 6516, signed March 4, 2021, and the guidance limiting its resident credit relief to the 2020 tax year, come from Hodgson Russ, "Finally, Connecticut Joins the Telecommuting Guidance Party": https://www.hodgsonruss.com/Noonans-Notes-Blog/finally-connecticut-joins-the-telecommuting-guidance-party.

Connecticut Department of Revenue Services, "Nonresidents who work in Connecticut," is the source of the two quoted ordinary-sourcing withholding rules for nonresident wages: https://portal.ct.gov/drs/withholding-taxes/nonresidents-who-work-in-connecticut.

New Jersey Division of Taxation, "Convenience of the Employer Sourcing Rule Enacted for Gross Income Tax FAQ," is the source of P.L. 2023, c.125 enacted July 21, 2023, the statement that "The new law is retroactive to January 1, 2023," the quoted mirroring mechanism, the coverage of Delaware, Nebraska, and New York residents, the Pennsylvania reciprocal-agreement exclusion, and the Connecticut exclusion "based on the reciprocal nature of Connecticut’s law": https://www.nj.gov/treasury/taxation/conveniencerulefaq.shtml. The refundable credit’s six quoted eligibility requirements, its tax year 2020 through 2023 coverage, the quoted "a credit of 50% of the additional tax that is owed to New Jersey," and the amended NJ-1040 filing mechanics come from the Division’s companion page: https://www.nj.gov/treasury/taxation/individuals/refundablegitcredit.shtml.

The state residency tests, top marginal rates, audit aggressiveness ratings, statutes of limitation, and enforcement method lists cited here come from ResidencyIQ’s own dossier research, with underlying citations on the New York, New Jersey, Connecticut, and California residency guides. That research is the source of New York Tax Law section 605(b)(1)(B) and the 2022 shift of "substantially all of the taxable year" to a period exceeding 10 months, the 20 NYCRR 105.20 any-part-of-a-day rule, Conn. Gen. Stat. section 12-701(a)(1) and the Connecticut regulatory carve-out for a genuinely temporary work apartment, N.J.S.A. 54A:1-2(m), California Revenue and Taxation Code sections 17014, 17016, and 19057(a), the New York 10.9% and New York City 3.876% rates, the New Jersey 10.75% rate, the Connecticut 6.99% rate, the California 13.3% effective top rate, the New Jersey enforcement method list, and the 12 to 24 month typical duration of a New York nonresident audit.