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The article focuses on the tax implications of gains and losses from subsidiary sales in New York. The franchise tax on corporations in New York according to Article 9-A of the Tax Law is computed based on the highest in four areas including allocated entire net income, allocated capital, and fixed-dollar minimum tax. The Bausch & Lomb case is presented wherein gains will be taxable and losses will reduce the income in the sale of a subsidiary stock included in a combined return.

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