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New York City tax appeals tribunal affirms exclusion of mortgage subsidiary from combined city bank tax return

The New York City (NYC) Tax Appeals Tribunal has affirmed the determination of the chief administrative law Judge’s previous decision in Matter of Astoria Financial Corp., holding that a federal savings and loan association was not required to include its Connecticut subsidiary in its combined NYC banking corporation tax returns for the 2006-08 tax years. The tribunal concluded that the investment subsidiary had both economic substance and its own business purpose separate and apart from that of its parent corporation, and did not cause distortion of income.

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