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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

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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…