New York City Announces Anticipated Deviations from Recently Promulgated New York State Corporate Tax Regulations
The New York City Department of Finance is expected to deviate from the New York State corporate tax reform regulations in several key areas, including the application of unincorporated business tax sourcing rules for corporate partners, authorizing deviations from statutory apportionment methods based on individual facts and circumstances, allocating income from passive investment customers using an 8% fixed allocation, increasing the threshold for taxpayers to use a billing address “safe harbor,” and retaining excess inclusion in income for holders of residual interests in real estate mortgage investment conduits.