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New York State Office of Counsel issues apportionment guidance for owners of registered broker-dealer SMLLCs

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On Aug. 2, 2017, the New York State Department of Taxation and Finance’s Office of Counsel issued an informational statement that provides guidance on the apportionment rules to be applied when a corporate taxpayer holds an ownership interest in a single-member limited liability company (SMLLC) that is federally registered as a securities or commodities broker-dealer. The guidance prohibits the corporate taxpayer from using the SMLLC’s broker-dealer classification for purposes of apportioning the receipts from its own specific activities, as well as receipts generated from related entities other than the SMLLC. The guidance covers both New York State pre-tax and post-tax reform years, and thus is applicable to taxable years beginning prior to, and on or after Jan. 1, 2015.