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Q&A

Chair Lee on Section 1127 miscalculation affecting 40,000 city employees

New York City Council · Jun 9, 2026 · starts 0:17:55 · 3 min 13 sec

Lee asks about a 10-year miscalculation of Section 1127 returns that resulted in over $100 million in lost revenue. Commissioner Lee explains the STAR benefit was incorrectly applied on both state and city sides after a 2016 shift, the error was discovered during an internal review, and corrections apply only to tax year 2025 with no clawback for prior years.

Linda Lee

All right, so moving on to Section 1127 returns.

Linda Lee

As a condition of city employment, any employee who is not a resident of New York City is required to make a payment equivalent to what their New York City income tax would have been if they were a city resident.

Linda Lee

It is the council's understanding that DOF has been incorrectly calculating Section 1127 returns for 10 years, which has resulted in more than $100 million in lost revenue to the city.

Linda Lee

This error was recently fixed, which has led to some city employees seeing a reduction in their tax refund or even charges to their account as a means for the city to take.

Linda Lee

The missing revenue.

Linda Lee

I feel like that impacts some folks here too.

Linda Lee

Can you please explain how the 1127 bills were supposed to be calculated and what was wrong to lead to a 10-year miscalculation?

Richard Lee

Yeah, so the 1127 waiver is essentially a contractual condition of employment for employees who live outside of New York City.

Richard Lee

The city charter requires that New York City employees who live outside the five boroughs have to pay the equivalent of their New York City personal income tax liability.

Richard Lee

So each filing year, employees would...

Richard Lee

then withhold a portion of the income.

Richard Lee

And so if they withhold, to cover this tax liability, so if they withhold greater than the tax liability, they get a refund.

Richard Lee

If they withhold less, then they'll have to pay into it.

Richard Lee

As part of that process, the school tax relief, the STAR benefit, was calculated against the city's personal income tax up until 2016.

Richard Lee

After 2016, it was shifted to be a credit that's calculated against your state personal income tax.

Richard Lee

So they're essentially receiving on the state side, but our systems kept continuing to provide this on the city side as well.

Richard Lee

So essentially they're receiving the STAR credit from both the state and the city.

Richard Lee

Earlier this year, we made the discovery that the city was still calculating this benefit off the 1127 return.

Richard Lee

We notified City Hall and then we recalculated the refunds and balances owed this year for this tax year for 2025.

Richard Lee

No other changes are going to be made on the Section 1127 for tax years before 2025.

Linda Lee

Okay, so they're not going to be penalized for not having, I mean, for taking the...

Richard Lee

Yeah, we're only correcting it for this year.

Richard Lee

We're not doing a clawback for any previous years.

Linda Lee

Okay, how was the mistake discovered?

Richard Lee

I'm sorry?

Linda Lee

How was the mistake discovered?

Richard Lee

Oh, so it was discovered while we were doing an internal review of the 1127 way before.

Linda Lee

Got it.

Linda Lee

Okay.

Linda Lee

What's the exact amount of the lost revenue as a result?

Linda Lee

Do you know?

Richard Lee

It averages just about like $10 to $12 million a year.

Richard Lee

It's different per year.

Linda Lee

And to $12 million per year.

Richard Lee

Per year.

Linda Lee

Okay.

Linda Lee

And then does DOF or OMB have any plans?

Linda Lee

No, you already answered that part.

Linda Lee

So who is responsible now for the administration of the 1127 waiver?

Richard Lee

That still remains Department of Finance.

Richard Lee

Okay.

Richard Lee

DOF is the primary administrator of the 1127 waiver.

Linda Lee

Okay, and how many employees are currently under 1127?

Linda Lee

Lever?

Richard Lee

Right now, I think it's just about 40,000.

Linda Lee

40,000.

Linda Lee

Okay, perfect.