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No. The current aggregate theory approach is continued and partnership items of receipts, income, gain, loss, and deduction, including attributes related to payroll and property factors, flow through a partnership to a corporate partner.

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The credit carryforward provisions were included in the new Subchapter 3-A. Any credit carried forward from a year prior to corporate tax reform may continue to be carried forward and used against the tax imposed under Subchapter 3-A in tax years 2015 and after, under the same rules that applied prior to reform.

Credits with carryforwards of unlimited duration can continue to be carried forward until used
Credits with carryforwards of a limited duration can be carried forward and used until their expiration.
Example:
A taxpayer, who relocated in 2008, was allowed a $3,000 Lower Manhattan Relocation and Employment Assistance tax credit in 2013 that has a 5-year carryforward duration. The taxpayer used $1000 in 2013 and $500 in 2014. The unused credit carryforward of $1,500 may continue to be carried forward until 2018, or whenever it is completely used, whichever comes first. Further, the twelve year benefit period also carries over into Subchapter 3-A.

The tax rate applicable to a qualified New York manufacturing corporation depends upon both the amount of its business income allocated to the City and the amount of its total business income prior to allocation. Administrative Code sections 11-654(1)(k)(1), (2) and (3) require separate alternative tax rate calculations using each amount. To determine its applicable tax rate, the corporation must, first, calculate its tax rate with reference to business income allocated to the City, second, calculate its tax rate with reference to business income prior to allocation, and, third, select the highest rate resulting from these calculations. Each calculation is necessary even if the corporation’s allocated business income is less than $10 million. Accordingly, the tax rate based on total business income prior to allocation sets a minimum, not a maximum, tax rate. No tax rate reduction applies at all if the corporation’s income allocated to the City is $20 million or greater or its business income prior to allocation is $40 million or greater.

Example A:
A qualified New York manufacturing corporation has $15 million of business income allocable to the City and $25 million of total business income. It must calculate alternative tax rates using each amount of income. The applicable tax rate is 6.638% because:
Tax rate based on business income allocated to the City. 4.425% + (4.425% x ([$15 million - $10 million] / $10 million)) = 6.6375% (round to 6.638%),
Tax rate based on total business income prior to allocation. 4.425% + (4.425% x ([$25 million -
$20 million] / $20 million)) = 5.53125% (round to 5.531%), and
The higher rate is 6.638%.

Example B:
A qualified New York manufacturing corporation has $15 million of business income allocable to the City and $35 million of total business income. It must calculate alternative tax rates using each amount of income. The applicable tax rate is 7.744% because:
Tax rate based on business income allocated to the City. 4.425% + (4.425% x ([$15 million - $10 million] / $10 million)) = 6.6375% (round to 6.638%),
Tax rate based on total business income prior to allocation. 4.425% + (4.425% x ([$35 million -
$20 million] / $20 million)) = 7.74375% (round to 7.744%), and
The higher rate is 7.744%.

Example C:
A qualified New York manufacturing corporation has $15 million of business income allocable to the City and $41 million of total business income. The applicable tax rate is 8.85% because total business income is $40 million or greater.

Example D:
A qualified New York manufacturing corporation has $25 million of business income allocable to the City and $25 million of total business income. The applicable tax rate is 8.85% because business income allocated to the City is $20 million or greater.

Example E:
A qualified New York manufacturing corporation has $8 million of business income allocable to the City and $25 million of total business income. It must calculate alternative tax rates using each amount of income.
The applicable tax rate is 5.531% because:

Example F:
A qualified New York manufacturing corporation has $8 million of business income allocable to the City and $15 million of total business income. It must calculate alternative tax rates using each amount of income. The applicable tax rate is 4.425% because:

The City intends to issue rules that generally correspond to the regulations New York State will issue under Article 9-A of the Tax Law to implement corporate tax reform, in so far as the underlying statutes themselves correspond. The City will make draft regulations available after the State has finalized its new and revised regulations and indicates that it will initiate adoption under the formal New York State Administrative Procedures Act. As they are developed, drafts of various regulatory amendments will be posted to the New York State Department of Taxation and Finance website for public comment. These draft regulatory amendments are not final and should not be relied upon.

A large corporation is one that had, or whose predecessor had, business income allocated within the City, of at least $1 million for any of the three tax years immediately preceding the tax year for which the exception is being sought. See, Administrative Code § 11-676(5)(a).