Redacted Letter Rulings

Written by Finance's Legal Affairs Division, letter rulings are written statements that set forth the applicability of the statutes and rules to a specific set of facts, and are provided in redacted form to protect taxpayer-specific information.

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Unincorporated Business Tax (UBT)

The sale of its assets by an entity eligible to claim a REAP credit constitutes a sale of the business for REAP purposes, permitting the purchasing entity to continue the selling entity’s REAP eligibility, where the purchasing and selling entities were under the same management and control, carried on the same business operations, operated from the same space, used the same phone number and utilities account, and employed the same personnel.  #09-4902  12/14/10
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Settlement fund, established to receive and invest proceeds from lawsuit pending disbursement, is not subject to GCT or UBT. #06-4854. 8/1/2006
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Hypothetical ruling holds that the treatment of a taxpayer's real estate salespersons as independent contractors for federal purposes under IRC §3508 has no bearing on the status of these salespersons as employees for UBT purposes. #06-4848. 5/17/2006
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Based on the substance of a transaction, a newly formed single member limited liability company was held to be an eligible business for purposes of REAP based on 100% continuity of ownership and 100% continuity of the business of wholly related entities. #05-4844. 5/1/2006
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This ruling addresses how REAP shares are calculated for a business where the business and the associated employees being relocated are transferred within a group of closely affiliated entities in connection with the relocation. #04-4830. 5/6/2005
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For a partnership properly using the 3 factor formula allocation method, receipts for services performed by partners and employees in a non-NYC office are allocated outside of NYC. #02-4792. 6/18/2002
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Settlement fund, established to receive and invest proceeds from lawsuit pending disbursement, is not subject to GCT or UBT. #01-4777. 11/26/2001
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An LLC that does not sell to or engage in trades on behalf of customers, nor maintain any inventory of securities for sale to potential customers, is exempt from paying Unincorporated Business Taxes. #00-4767. 10/10/2000
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Gain on the sale of a business, and interest income received with respect to installment obligations relating to the sale of the business are included in New York City unincorporated business income in the same manner as they are included in federal income. #99-4754. 11/4/1999
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Partnership's cancellation of indebtedness income is excluded from taxable income to the extent required by the Bankruptcy Code. #98-4725. 12/15/1998
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