Corporation tax advisory opinions - 2018 (TSB-A)An Advisory Opinion is issued at the request of a person or entity. It is limited to the facts set forth therein and is binding on the Department only with respect to the person or entity to whom it is issued and only if the person or entity fully and accurately describes all relevant facts. An Advisory Opinion is based on the law, regulations, and Department policies in effect as of the date the Opinion is issued or for the specific time period at issue in the Opinion.
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|TSB-A-18(1)C(4)I||Petitioners ask whether, as a member of a unitary group making a combined report, Subsidiary's income from a line of business that it previously conducted, created or developed is income that must be disregarded when computing its tax factor for the Tax-free NY area tax elimination credit under the START-UP NY program and whether proportional recovery of tax benefits in a given taxable year would preclude eligible Subsidiary employees from claiming, in that year, an exemption from the New York State personal income tax, the New York City personal income tax, the Yonkers city income tax, and the Yonkers nonresident earning tax.|