Navigating Impact of New York Corporate Tax Overhaul: New Apportionment and Reporting Rules

Mastering Unitary Reporting, Market-Based Sourcing, and Changes to NY State Treatment of Nonresident S Corp Shareholders

Recording of a 110-minute CPE webinar with Q&A

Conducted on Thursday, February 9, 2017

Recorded event now available

or call 1-800-926-7926
Course Materials

This course will provide corporate tax advisers with a thorough and practical guide to the latest developments in New York State’s multi-year tax reform initiative. The panel will discuss the broader framework of New York’s corporate tax reform changes and will address the provisions scheduled to go into effect with the 2016-2017 Budget Act. The event will outline various elections effective for 2017, detail changes to balance sheet reporting, review treatment of nonresident S corporations conducting business in New York State, and point out filing deadline changes.


In recent years, New York enacted and implemented a major corporate tax reform bill. The bill represented a significant overhaul of the rules for taxing the income of C corporations and may have implications for sourcing income to New York by nonresident shareholders of S corporations. The reform went into effect for 2015 and has a multi-year implementation period. Corporations doing business in the state of New York need to understand the changes under the corporate tax overhaul.

The key features of the broad-based changes to New York’s corporate tax structure are: adoption of economic nexus jurisdictional rules activated if a corporation has receipts of $1 million or more in a tax year from New York activities; substitution of a unitary combined reporting regime for the existing combined reporting rules; and expansion of the single receipts factor apportionment formula generally based on market-based sourcing to all receipts, particularly receipts from services and intangibles.

New York City’s corporate tax provisions were also recently changed, but there remains some significant areas of misalignment between the State and City rules. Unless and until there is conformity, differences between state and city tax treatment will create a filing and administrative burden for businesses that must compute their overall state and city liability under these two different tax regimes.

Listen as the panel provides a practical guide to the latest developments in New York State’s ongoing corporate tax reform initiative, discussing changes upcoming in 2017, and offering useful tools for navigating apportionment and reporting requirements.



  1. Major 2014-2015 New York corporate income tax changes for out-of-state businesses
    1. Expansion of the single receipts factor apportionment formula
    2. Substitution of a unitary combined reporting regime for the existing combined reporting rules
    3. Adoption of economic nexus jurisdictional rules
    4. Repealing the bank franchise tax, bringing all corporations under the corporate franchise tax
  2. The 2015 legislation amendments: corporate franchise tax and other taxes
    1. Investment capital
    2. Investment income
    3. Qualified financial instrument
    4. Other changes
  3. Specific examples


The panel will review these and other key issues:

  • Assessing the Act’s impact on state income tax reporting procedures
  • Evaluating the Act’s changes involving: economic nexus thresholds, market-based sourcing apportionment rules, corporate partner nexus reporting, and unitary combined reporting provisions
  • Identifying and reconciling differences between state and city tax treatment in New York City and the state of New York


Christopher L. Doyle
Christopher L. Doyle

Hodgson Russ

Mr. Doyle leads his firm's SALT team. His practice spans most tax matters, but focuses primarily on New York...  |  Read More

Pascal, Elizabeth
Elizabeth Pascal

Hodgson Russ

Ms. Pascal concentrates her practice in tax law with a focus on New York State, New York City, and multistate tax...  |  Read More

Nicholas Montorio
Nicholas Montorio
STS-SALT Manager

Mr. Montorio advises the firm’s clients on a variety of multistate tax matters involving business activity taxes...  |  Read More

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