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(§ 11-641(f) and (k), Administrative Code)
(a) The adjusted eligible net income of the IBF is allowed as a deduction in computing the taxpayer's entire net income, to the extent not deductible in determining Federal taxable income. This deduction is taken before the taxpayer allocates its entire net income within and without New York City. The adjusted eligible net income of the IBF is determined by subtracting from the eligible net income of the IBF the ineligible funding amount (See: 19 RCNY § 15-10, infra – Ineligible Funding Amount) and the floor amount (See: 19 RCNY § 15-11, infra – Floor Amount). The eligible net income of the IBF is the amount remaining after subtracting from the eligible gross income of the IBF (See: 19 RCNY § 15-04, infra – Eligible gross income) the expenses applicable to such gross income (See: 19 RCNY § 15-05, infra – Direct expenses of the IBF, 19 RCNY § 15-06, infra – Interest Expense of the IBF, 19 RCNY § 15-07, infra – Bad Debt Deduction of the IBF, and 19 RCNY § 15-08, infra – Indirect Expenses of the IBF, including Head Office Expenses). When the IBF has eligible gross income and ineligible gross income for the taxable year, eligible net income of the IBF is computed by reducing eligible gross income by those expenses which are apportioned to eligible gross income pursuant to 19 RCNY § 15-09, infra.
(b) The eligible gross income of the IBF is the amount of gross income (including gross income from interoffice transactions) derived from the activities described in 19 RCNY § 15-04, infra, that would be includible in the computation of the IBF's entire net income for the taxable year, as if the IBF were a separate corporation.
(c) Expenses applicable to the eligible gross income of the IBF are those expenses or other deductions (including expenses or other deductions from interoffice transactions) described in 19 RCNY §§ 15-05, 15-06, 15-07, and 15-08, infra, that are directly or indirectly attributable to the eligible gross income of the IBF.
(d) The Commissioner of Finance may, whenever necessary in order to properly reflect the adjusted eligible net income or the entire net income of the taxpayer, determine the taxable year in which any item of income or deduction shall be included without regard to the method of accounting used by the taxpayer.
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