New York State Corporate Tax Reform Outline Part A of Chapter 59 of the Laws of 2014 Signed March 31, 2014 April 2014

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1 Corporations Subject to [Bill 1 and 5; Law (TL) 209 unless otherwise noted] Unifies Articles 9-A (Corporate Franchise ) and 32 (Bank Franchise ). o Current Article 32 taxpayers are subject to the revised Article 9-A. Clarifies nexus standards. o Adopts economic nexus for all taxpayers. The existing Article 9-A nexus standard (exercising a corporate franchise, doing business, employing capital, owning or leasing property, or maintaining an office) is expanded to include deriving receipts from activity in New York. De minimis New York receipts threshold set at $1 million based upon the existing economic nexus provisions for credit card banks under Article 32. Threshold subject to annual review. o Repeals the fulfillment service nexus rule in Article 9-A. o Clarifies that alien corporations not deemed domestic under the Internal Revenue Code (I.R.C.) with no effectively connected income (ECI) computed pursuant to I.R.C 882 are not subject to tax. In addition, such alien corporations are excluded from the combined group. [Bill 18; TL 210-C.2(c)] Alien corporations are defined as corporations organized under the laws of a country, or any political subdivision thereof, other than the United States, or organized under the laws of a possession, territory, or commonwealth of the United States. Classification of Income and Expenses Business Income [Bill 4; TL 208.7, 208.8, and unless otherwise noted] The starting point for the business income base is federal taxable income (FTI) for U.S corporations and ECI for alien corporations not deemed domestic under the I.R.C. o payers are required to add back treaty benefits to ECI, consistent with the current treatment of alien banks under Article 32. o The requirement that taxpayers add back the amount of foreign taxes paid is eliminated. o Most of the other existing 9-A modifications are continued. The current exemptions for income from subsidiary capital and 50% of dividends from non-subsidiaries are eliminated. o The income is re-classified as investment income, other exempt income, or business income. Business income equals entire net income (ENI) minus investment income and other exempt income. Discrete components of business income are not articulated, but business income includes the following: o interest income and gains and losses from debt instruments or other obligations, unless the income cannot be included in apportionable business income under the U.S. Constitution; o gains and losses from stock of a unitary corporation; o dividends and gains and losses from stock held in a non-unitary corporation for 6 months or less; and o cash. -1-

2 To prevent the overcapitalization of non- life insurance corporations under the new regime, the Commissioner is provided with discretionary powers to make a deemed distribution of nonpremium income from overcapitalized Article 33 corporations to the affiliated Article 9-A corporations to properly reflect the activities of the unitary business. [Bill 19; TL 211.5] The current approach to partnership items of receipts, income, gain, loss, and deduction that flow through a partnership to a corporate partner as well as gains or losses from the sale of a partnership interest itself (i.e., the current regulations) is retained. [Bill 5 and 15-a; TL 209.1(f)) and 210.3] Allocated business income is the amount subject to tax. [Bill 12; TL 210.1(a)] Investment Income [Bill 4; TL and unless otherwise noted] The current Article 9-A definition of investment income is narrowed to include only income from stocks of non-unitary corporations held for more than 6 consecutive months and income that cannot be included in apportionable business income under the U.S. Constitution. o Stock is defined as an interest in a corporation that is treated as equity for federal income tax purposes. [Bill 4; TL 208.4] o Solely for purposes of the definition of investment capital and investment income, if the taxpayer owns or controls, directly or indirectly, less than 20% of the voting power of the stock of a corporation, the corporation is assumed to not be conducting a unitary business with the taxpayer. The unitary determination for corporations 20% or more owned is fact-specific, with no presumption. o For purposes of determining the 6 month holding period, offsetting positions the taxpayer takes in such or similar securities are taken into account. o The 6 month holding period for stocks is measured across tax years. Where the holding period is split across tax years, a taxpayer is allowed to classify income from stock as investment income in the first year if it intends to hold the stock for more than 6 months. If the stock is not held for more than 6 months, the dividends and gains and losses from the stock generated in year 1 and year 2 are required to be included as business income in year 2. Other Exempt Income [Bill 4; TL a] The new other exempt income category of income is defined as the sum of exempt CFC income and exempt unitary dividends. o Exempt CFC income is income received from a controlled foreign corporation that is conducting a unitary business with the taxpayer but is not included in the combined group. This includes Subpart F income and 956 dividends. o Exempt unitary dividends are dividends from unitary corporations not in the combined group because they are: (1) taxable under another tax article; (2) alien corporations not deemed domestic with no ECI; or (3) less than 50% directly or indirectly owned. -2-

3 Attribution of Expenses [Bill 4; TL 208.6, a, and unless otherwise noted] Investment income and other exempt income are not taxable and the deductions for interest expenses attributable to such income are disallowed. o If actual expense attribution exceeds income, the excess expenses are required to be added back to income. o In lieu of computing actual interest expenses disallowed, taxpayers generally can elect to reduce investment and other exempt income by 40%. If the election is made, it covers both other exempt income and investment income. payers receiving dividends from unitary affiliates subject to tax under Article 9 or Article 33 are precluded from making the 40% election for those dividends and must perform actual expense attribution. o The actual attribution methodology for taxpayers not making the 40% election will be based on current rules and detailed in revised guidance issued by the Department. o The computation of expense attribution for a combined group is done on a one company basis. If the taxpayer chooses the 40% election, it applies to both the investment income and other exempt income of all members of the combined group. [Bill 18; TL 210-C.4(e)] Bases and Rates Bases The Article 9-A alternative minimum tax (AMT) base, the Article 32 alternative entire net income base, the Article 32 taxable assets base, and the Article 32 fixed dollar minimum tax are eliminated. [Bill 1 and 12; TL 210.1(c)] The separate tax on subsidiary capital is repealed. [Bill 12; TL 210.1(e)] The business income base is the primary tax base, with the business capital and fixed dollar minimum tax bases as alternatives. o An alternative base credit for taxes paid to other states on identical bases is added to address possible constitutional challenges to these taxes. [Bill 17; TL 210-B.42] Business Income Base [Bill 12; TL 210.1(a) unless otherwise noted] The following tax rate schedule applies to the business income base: Type of Business and Thereafter Qualified New York Manufacturers 0.0% 0.0% 0.0% 0.0% Qualified Emerging Technology 5.7% 5.5% 5.5% 4.875% Companies (QETCs) Small Businesses 1 6.5% 6.5% 6.5% 6.5% Remaining payers 7.1% 6.5% 6.5% 6.5% 1 For the 2015 tax year, current law graduated rates applies to small businesses with income over $290,000 but below $390,000. A flat 6.5% rate applies to tax years beginning on or after January 1,

4 Qualified New York manufacturers must meet the existing property and receipts tests. o Either all or at least $1 million of manufacturing property is in New York; and o At least 50% of receipts must be from manufacturing. A taxpayer, or combined group, that fails the receipts test may still be a qualified New York manufacturer if it has at least 2,500 New York manufacturing employees and at least $100 million of manufacturing property in New York. A taxpayer is a qualified emerging technology company if it meets the definition in Public Authorities Law Section 3102-e(1)(c), without regard to $10 million limitation under 3102-e(1)(c)(1). A small business taxpayer is defined as a taxpayer with (1) business income of $390,000 or less, (2) $1 million or less in the aggregate amount of money and other property it received for stock, as a contribution to capital and as paid-in surplus, and (3) 100 or fewer New York employees. The taxpayer cannot be part of an affiliated group unless the group, if it had filed a combined return, met the small business test. [Bill 12; TL 210.1(f)] Capital Base [Bill 12; TL 210.1(b)] The following rate schedule applies to the capital base: Type of Business and Thereafter Qualified New York 0.15% 0.106%.085%.056%.038%.019% 0% Manufacturers & QETCs Cooperative 0.04% 0.04% 0.04% 0.04% 0.04%.025% 0% Housing Corporation Remaining 0.15% 0.125%.1%.075% 0.05%.025% 0% payers The tax is capped at $350,000 for qualified New York manufacturers and QETCs and $5 million for all other taxpayers. Small business taxpayers are exempt from the capital base tax in their first two years. Fixed Dollar Minimum (FDM) [Bill 12; TL 210.1(d)] Qualified New York manufacturer C corporations and QETCs are subject to the following FDM schedule: New York Receipts and Thereafter Not more than $100,000 $22 $21 $21 $19 $100,001 - $250,000 $66 $63 $63 $56 $250,001 - $500,000 $153 $148 $148 $131 $500,001 - $1,000,000 $439 $423 $423 $375 $1,000,001 - $5,000,000 $1,316 $1,269 $1,269 $1,125 $5,000,001 - $25,000,000 $3,070 $2,961 $2,961 $2,625 Over $25 million $4,385 $4,230 $4,230 $3,750-4-

5 Remaining C corporation taxpayers are subject to the following FDM schedule: New York Receipts 2015 and Thereafter Not more than $100,000 $25 $100,001 - $250,000 $75 $250,001 - $500,000 $175 $500,001 - $1,000,000 $500 $1,000,001 - $5,000,000 $1,500 $5,000,001 - $25,000,000 $3,500 $25,000,001 - $50,000,00 $5,000 $50,000,001 - $100,000,000 $10,000 $100,000,001 - $250,000,000 $20,000 $250,000,001 - $500,000,000 $50,000 $500,000,001 - $1,000,000,000 $100,000 Over $1 billion $200,000 The FDM amounts are unchanged for S corporations. Apportionment of Business Income [Bill 16; TL 210-A unless otherwise noted] Business income is apportioned based on a single receipts factor using customer sourcing rules. Receipts from sales of electricity are sourced to the delivery location. Net gains (not less than zero) from the sales of real property are sourced to the location of the property. Royalties from the use of patents, copyrights, trademarks, and similar intangibles are sourced to New York if such intangibles are used within the state. Receipts from digital products are generally sourced to the customer s primary use location of the product. New sourcing rules are created for apportioning income from financial instruments. o Qualified financial instruments (QFIs) are defined as financial instruments that are marked to market under I.R.C. 475 or 1256, excluding loans secured by real property. o payers can use one of two sourcing methods for QFIs: customer-based sourcing for each income stream that does not constitute tax exempt income; or elect to treat all income from QFIs as taxable business income and apportion 8% of the net income (dividend income, interest income, and net gains), not less than zero, from QFIs to New York. o The 8% QFI election must be made on an annual basis, is irrevocable, and applies to all the QFI income of all members of a combined group. o Non-qualified financial instruments (non-qfis) are all financial instruments that do not meet the definition of QFI and the related income is subject to customer-based sourcing. In cases where sourcing rules for financial transactions rely on commercial domicile, taxpayers are required to use the following hierarchy: o location of the treasury function; o seat of management and control; and o billing address of the customer. Receipts constituting the primary spread of selling concession from underwritten securities are sourced to the customer s location. -5-

6 Receipts from credit card authorization processing and clearing and settling processing are sourced to the location where the credit card processor s customer accesses the processor s network. All other credit card processing receipts are sourced to New York using the average of 8% and the percentage of New York access points. Receipts from services are generally sourced to New York if the customer receives the benefit of the service in the State. The special apportionment rules for trucking, railroad, transportation of gas through pipes, and aviation are used as the basis for the new receipts rules for these industries. Current sourcing rules continue generally for: o sales of tangible personal property; o rentals of real and tangible personal property; o broker/dealer activities, except as described above; o interest, fees, penalties, service charges, merchant discounts, and credit card fees; o services provided to a Regulated Investment Company (RIC); and o advertising. Combined Reporting [Bill 18; TL 210-C unless otherwise noted] New York is adopting a full unitary water s-edge method for combined reporting. The requirements to be combined are: o unitary business test; and o more than 50% stock ownership test based on voting power. One corporation directly or indirectly owns another or corporations are controlled by a common interest or by related parties. o The substantial intercorporate transactions test is eliminated. The New York combined group must include all domestic corporations, alien corporations deemed domestic corporations under the I.R.C. (contiguous, stapled, and inverted corporations), alien corporations with ECI, captive REITs and RICs not combinable under Article 33, and combinable captive insurance companies. o The current captive REIT/RIC combination requirement is incorporated without the special exclusion for affiliated groups whose members own assets under $8 billion. o The combined reporting requirements for captive insurance companies is changed to require combination with captive insurance companies, where less than 50% of the captives premiums are from arrangements that constitute insurance for federal income tax purposes. [Bill 20, 21, and 22; TL 2, 1500(a), and 1502-b(a)] o Cross article combination remains prohibited. o Single receipts factor apportionment for all taxpayers (see above) allows aviation, railroad, and trucking companies to be included in the combined group. -6-

7 payers can also make a commonly owned group election covering a 7 year period. o The group must include all unitary and non-unitary corporations that could be taxed under Article 9-A and that meet the ownership test. o The election must be made when the original return is timely filed and may not be revoked during the 7 year period. Upon expiration, the election is automatically renewed for another 7 years unless the group affirmatively declines. If the election is affirmatively declined, a new election cannot be made for 3 years. o Each corporation in the group is deemed to have agreed to treat the income from the nonunitary businesses as if it were from the group s unitary business and any corporation conducting a non-unitary business that is acquired during that period that could be taxed under Article 9-A is included in the combined group for the remainder of the election period. The combined group is generally treated as if it were a single entity. o Each taxpayer member of the combined group is liable for the group's whole tax, not just its pro rata share of the combined group's tax. o The combined group must designate one taxpayer member to be the agent for administrative purposes (e.g., filings, assessments, payments, and waivers). o The combined group s tax is the sum of (1) the greater of the tax on combined business income, the tax on combined business capital, or the fixed dollar minimum tax of the agent and (2) the fixed dollar minimum tax for every other taxpayer member of the group. o Generally, combined income is computed using the federal intercorporate deferral rules. o Credits, prior net operating loss conversion subtractions, net operating loss deductions, and capital losses can be used by the group, not just the corporation that generated the item, and are applied in computing the combined tax. Prior Net Operating Loss Conversion (PNOLC) Subtraction [Bill 12; TL 210.1(a)(viii)] Net operating losses (NOLs) that were incurred before the 2015 tax year would be converted into a PNOLC subtraction to stabilize their value for financial accounting purposes. o payers must first compute the value of the unabsorbed NOL for the base year. This is computed by applying the taxpayer s (or combined group s) 2014 business allocation percentage and tax rate to the 2014 pre-apportionment New York NOL carryforward. The resulting product is then divided by 6.5% 1 This amount is referred to as the PNOLC subtraction pool. 1 Even though the bill includes a special computation for qualified New York manufacturers, the value of the PNOLC subtraction for such manufacturers is $0 because of the 0% ENI rate in effect for tax year

8 o payers have a choice to use 1/10 of the PNOLC subtraction pool in each year for the next 20 years or use 1/2 of the PNOLC subtraction pool in 2015 and If taxpayers cannot use the entire 1/10 allotment of subtraction in one year, the unused portion is carried forward into future years and added to the amount allowed in subsequent years. s where the subtraction cannot be used still count in determining the 20 year period. If taxpayers choose to deduct 1/2 of the subtraction in 2015 and 2016, any unused amount is lost after Qualifying small business taxpayers are not subject to the use limits. o Where two or more taxpayers and/or groups that existed in tax year 2014 constitute one group in 2015, each taxpayer and/or group would compute its PNOLC subtraction separately based on its 2014 information; in 2015, the group s total PNOLC subtraction is the sum of the subtractions of each of its constituent taxpayers and/or groups. If a taxpayer leaves the group after 2015, the taxpayer takes its proportionate amount of the subtraction with it. If a taxpayer enters the group after 2015, its proportionate amount of the subtraction is added to the group s remaining subtraction amount. o The PNOLC subtraction is a deduction against apportioned business income. NOL Deduction [Bill 12; TL 210.1(a)(ix)] The following rules apply to NOLs incurred in tax years beginning on or after January 1, 2015: o NOLs can be carried back 3 years, provided no NOL earned in 2015 or later can be carried back to a tax year before o NOLs can be carried forward 20 years. o A taxpayer s NOL deduction (NOLD) in any specific tax year would be the sum of apportioned business losses that were incurred in tax years beginning on or after January 1, 2015, less any portion of such losses that were deducted as a NOLD in a prior tax year. o The NOLD is no longer limited by the federal NOLD source year or amount. o The NOLD is a deduction against apportioned business income. o payers only have to use a NOLD in an amount necessary to bring the tax on business income down to the higher of the tax measured by capital or the fixed dollar minimum tax, with excess NOL carried forward. o NOLD is not allowed for a NOL sustained during any year in which the corporation generating the loss was not subject to tax in New York. o The current separate return limitation year (SRLY) rules used when corporations enter or leave a combined group are continued. -8-

9 Credits [Bill 15 and 17; TL 210 and 210-B] Credits are moved from current law 210 to a new 210-B. o This includes all credits allowed under current law as well as those enacted in the budget. Amounts of credit carry forwards that existed in pre-reform years are preserved, with the exception of the alternative minimum tax credit. Special Provisions Reform eliminates several special bank specific provisions, including: [Bill 1] o international banking facilities provisions; o deduction for interest income from government obligations; and o the exclusion from the mandatory S election for Article 32 Subchapter S corporations. The law clarifies that the investment income of a QSSS is included when determining an eligible S corporation s investment income for purposes of the mandatory S election test. [Bill 74, TL 660(i)] In an effort to encourage local lending in New York, three new ENI modifications are created for thrifts and community banks. o The first modification, eligibility for which is based on the eligibility for the prior New York State bad debt modification for thrift institutions, is available to thrifts and qualified community banks holding a qualified residential loan portfolio. [Bill 4; TL 208.9(r)] payers must choose to utilize this modification or the second modification discussed below. o The second modification is available to small thrifts and qualified community banks for holding a significant amount of New York small business loans and New York residential mortgages. [Bill 4; TL 208.9(s)] payers must choose to utilize this modification or the first modification discussed above. o The third modification is available to small thrifts and qualified community banks that maintained a REIT on April 1, [Bill 4; TL 208.9(t)] payers using this modification are precluded from using the two other modifications discussed above. Repeal of Nuisance es The organization tax and taxes on changes of capital on domestic corporations under TL 180 are repealed. [Bill 2] The license and maintenance fees on foreign corporations imposed by TL 181 are repealed. [Bill 3] MTA Surcharge [Bill 7, 8, 10, and 11; TL 209-B unless otherwise noted] An economic nexus standard also applies to the MTA surcharge. o The de minimis MTA receipts threshold is $1 million. The base of the MTA surcharge is New York State tax before credits for the current year. o payers are no longer required to recompute liability using prior tax rates and limitations. -9-

10 The surcharge is apportioned to the MTA using an equally weighted three factor formula consisting of payroll, property, and receipts. o The receipts factor uses the 210-A customer sourcing rules. To maintain revenue neutrality for the MTA, the new surcharge rate is 25.6% for tax year For tax years 2016 and thereafter, the Commissioner will adjust the rate based on economic projections in the enacted State budget for the relevant year. Article 9 and Article 33 MTA surcharges are also made permanent, although the rates and calculation methodologies remain unchanged. [Bill 61, 63, 65, and 88; TL 183-a, 184-a,186-c, and 1505-a)] Effective Date [Bill 113] These provisions are effective for taxable years beginning on or after January 1, Remaining Amendments Bill 99 is a continuation of Article 32 and 180 and 181 for assessment purposes. Bill 112 is the severability clause. Bill 110 and 111 extend the New York City Gramm-Leach-Bliley Act (GLBA) transitional provisions for two years. Remaining sections amend cross-references and repeal obsolete provisions. This outline is an informational document that provides an overview of the corporate tax reform proposal enacted as part of the budget. It is designed to provide general guidance and is not intended to interpret the law or change its meaning. -10-

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