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Niki Ford

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New York Appellate Court Affirms Entity‑Level QETC Requirements for Combined Groups

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In Matter of Charter Communications, Inc. v New York State Tax Appeals Tribunal, CV-24-0971 the New York Supreme Court, Appellate Division, Third Department (New York’s intermediate appellate court, the “Court”) recently held that Charter Communications, Inc. and its combined affiliates were not eligible for the reduced qualified emerging technology company (“QETC”) corporate franchise tax rate. The Court agreed that each member of a combined group must independently meet the QETC definition for the group to…

A Decade After Tax Reform, New York City Proposes New Business Corporation Tax Regulations

By , , , and 7 Mins Read

The New York City (“City”) Department of Finance (“DOF”) has taken a significant step forward in implementing its corporate tax reform provisions enacted in 2015 by proposing the first installment of its regulations under a new Chapter 11A of Title 19 of the Rules of the City of New York (“Proposed Rules”). These Proposed Rules come nearly two years after the New York State (“State”) Department of Taxation and Finance (“DTF”) adopted its final regulations…

SALT Implications of the One Big, Beautiful Bill Act

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On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act (hereinafter, “OBBBA” or “the Act”) into law. OBBBA enacts sweeping changes to the Internal Revenue Code (“Code”), many of which will impact taxpayers at the state level, including reforms to the federal state and local tax (“SALT”) deduction, Global Intangible Low-Taxed Income (“GILTI”), Foreign-Derived Intangible Income (“FDII”), section 174 research and development expensing, and section 163(j) business interest deduction limitations. Notably,…

New Year, Same New York—Bill Proposes Significant Tax Increases for Corporations

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Starting the new year off with legislation aimed directly at the pockets of corporate taxpayers, New York has issued a legislative proposal to nearly cut in half corporate taxpayers’ available GILTI exemptions, and at the same time almost double the top corporate franchise tax rate. Senate Bill 953 (“SB953”), pre-filed in the state senate on January 8, 2025, has the potential to significantly increase New York franchise tax exposure for corporations doing business in the…

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