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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Banking Corporation Tax (BCT)
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Unincorporated Business Tax (UBT)

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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