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Corporation tax advisory opinions - 2020 (TSB-A)

An Advisory Opinion is issued at the request of a person or entity.  It is limited to the facts set forth therein and is binding on the Department only with respect to the person or entity to whom it is issued and only if the person or entity fully and accurately describes all relevant facts.  An Advisory Opinion is based on the law, regulations, and Department policies in effect as of the date the Opinion is issued or for the specific time period at issue in the Opinion.

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Corporation tax advisory opinions - 2020 (TSB-A)
Number Issue
TSB-A-20(1)C Petitioner asks whether Petitioner's merger was formed for the purpose of operating a telegraph or telephone business and whether more than 50% of Petitioner's gross receipts are derived from other than Article 9 activities and should be classified as an Article 9-A filer as of the effective date of the merger
TSB-A-20(2)C,(1)I Petitioner asks whether the property specified in the Petition is located within a qualifying census tract for the tax credit for rehabilitation of historic properties.
TSB-A-20(3)C Petitioner asks whether if the structure of a sale by Petitioner "A" of the entirety of the issued and outstanding stock of Petitioner "B" to an unrelated third party conforms to the provisions of the Internal Revenue Code Section 338(h)(10), will New York follow the Federal tax treatment of said sale and whether if a distribution by Petitioner "B" to Petitioner "A" of certain assets prior to the sale conform with Internal Revenue Code section 338(h)(10), will New York follow the Federal tax treatment of said distribution. 
TSB-A-20(4)C,(13)I Petitioner asks whether certain costs constitute "site preparation costs" within the meaning of Tax Law Section 21(b)(2) and what is the last date that the site preparation credit may be claimed.