New York City: Proposed rules for business corporation tax
First subchapter of proposed rules issued for public consultation
The New York City Department of Finance (DOF) is proposing rules to implement changes made in 2015 to the city business corporation tax (BCT). The 2015 legislation aligned with changes made to New York State franchise tax, subjecting most of the former general corporation tax and banking corporation tax taxpayers to a single BCT, as well as adopting market-based sourcing.
The DOF plans to issue a series of rules that will collectively add a new Chapter 11A to Title 19 of the Rules of the City of New York (RCNY). Additional rules will be proposed by subchapter. The DOF plans to follow this proposed rule process in the coming months, issuing one or more separate proposals for the remaining eight subchapters with each proposal receiving a public comment period. Chapter 11A will not be final or enacted until all proposed rules of the chapter have been released and have gone through the public comment period.
The first subchapter proposed by the DOF is Subchapter 1 of Chapter 11A, which includes two parts:
- Part 1-1 provides definitions of relevant terms used throughout Chapter 11A of the regulations.
- Part 1-2 addresses the "Imposition of Tax” section of the statute, which covers minimum activities that would subject corporations to the tax, as well as specific exemptions from the tax.
A public hearing on proposed Subchapter 1 of Chapter 11A is set for November 20, 2025, 11:00AM ET, via Microsoft Teams. The DOF is accepting public comments on the proposed rule until November 20, 2025.
Read a November 2025 report prepared by KPMG LLP