New York State provides guidance on broker-dealer receipts sourcing

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August 2017

Overview

The New York State Department of Taxation and Finance (Department) recently published a memorandum, Receipts Factor Methodology For The Owners of Single Member Limited Liability Companies That Are Registered Broker-Dealers, to its website regarding the broker-dealer sourcing provisions for New York State Corporation Franchise Tax purposes. The Department is advising taxpayers that certain previously issued Advisory Opinions regarding sourcing of broker-dealer receipts no longer reflect the Department’s current position. Taxpayers should therefore be advised that the Department is now distancing itself from previously published Advisory Opinions.

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Brian Rebhun

Asset Management Tax Leader, PwC US

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