NY Experts? State Apportionment

Technical topics regarding tax preparation.
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16-Jul-2018 8:34am
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Have a pre-revenue client that has raised a lot of capital ($15MM+) and is a NY filer. The only gross receipts they have is interest income from bank deposits.

I'm not find a clear answer on whether this type of gross income is included in the sales factor calculation and if it is, how it is sourced. Taxpayer moved its corporate domicile to NJ in December 2022 but was a domestic NY corporation for most of 2022.

With the NY capital base tax I'm either looking at $30K plus in tax if interest income IS included and is NY sourced vs. the $25 minimum tax if its not.

Ultratax doesn't carry the interest income entry in the apportionment screen to the NY forms but I'm still not fully convinced it shouldn't be part of the sales factor.

Any advice on this beautiful day is greatly appreciated!
 

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