BIG for conversion from C to S in NYS?

Client is S corp for fed since 2015. The client began doing business in NYS in 2017 at which time the preparer filed NY C corp returns. If there is a conversion from C to S for NYS purposes is there a BIG issue for NYS?I don't think so since NY general business return is a franchise tax but would of course like to be sure. Does anyone have any experience with this?

The wording is kind of tough to plow through, but I think NY section 612(b)(18) makes you follow the bouncing ball, and results in the shareholder adding back the federal deduction for BIG tax to AGI. And this advisory opinion says that does not increase NY basis. https://www.tax.ny.gov/pdf/advisory_opi ... a11_1i.pdf.

But check me on it.

The wording is kind of tough to plow through, but I think NY section 612(b)(18) makes you follow the bouncing ball, and results in the shareholder adding back the federal deduction for BIG tax to AGI. And this advisory opinion says that does not increase NY basis. https://www.tax.ny.gov/pdf/advisory_opi ... a11_1i.pdf.

But check me on it.

Thanks Nilo. But there is/was no BIG tax for fed because it was never a C corp for fed. The company has been taxed as a federal S corp since inception. Am I missing the boat on what you're getting at here?

No, I overlooked that fact.

No, I overlooked that fact.

Thanks. Any other thoughts on this issue? I'd like to elect S status in NY but want to make sure I'm not missing any gotchas.