New York City - Unregistered partnership may use broker-dealer sourcing

June 2014


​In a letter ruling, the New York City Department of Finance concluded that a taxpayer is considered a broker-dealer for Unincorporated Business Tax purposes, although it is not formally registered as such with the Securities and Exchange Commission or the Commodities Futures Trading Commission. Consequently, the taxpayer may utilize the special receipts sourcing method for services available to broker-dealers, which is based on the mailing addresses of its customers rather than where the services are performed. (Finance Letter Ruling, NYC Dep't of Fin. FLR 12-4934/UBT, Aug. 19, 2013, released June 12, 2014).

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