UniCredit Case A Win For NY Bank Taxpayers

Law360, New York (November 20, 2013, 7:21 PM EST) -- In a recent decision, the New York State Division of Tax Appeals soundly rejected a determination by the New York State Department of Taxation and Finance that it could treat a banking corporation’s international banking facility as having ineligible gross income in order to allow the use of scaling ratios to compute the bank’s allocation factors.[1]

In rejecting the department’s position, the administrative law judge ruled that under the formula allocation method elected by the taxpayer, the IBF’s interbranch transactions and transactions that produced noneffectively connected...
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