New York City imposes a tax on unincorporated businesses, but avoids double taxation by permitting an exemption equal to amounts "included in [the] corporate partner's net income". (Administrative Code of City of NY § 11-510 [2].) Where a corporate partner pays all of its income out to its principals in salaries, it has no net income, yet a corporate business tax is nevertheless imposed by means of a formula whereby salaries, less a $15,000 statutory exclusion, are ...
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