Sec. 18-3.9. Apportionment of expenses of the IBF

Tax Law, § 1453(f)

When the IBF has eligible gross income and ineligible gross income, the expenses that are applicable to eligible gross income shall be the sum of the following amounts:

(a) the amount of direct expenses of the IBF (as determined in sections 18-3.5, 18-3.6[b][1] and 18-3.7 of this Subpart) for the taxable year that are specifically identified with eligible gross income; and

(b) an amount computed by multiplying the sum of direct expenses of the IBF (as determined in sections 18-3.5 and 18-3.6[b][1] of this Subpart) for the taxable year that are not specifically identified with either the eligible gross income or the ineligible gross income of the IBF and all indirect expenses of the IBF (as determined in sections 18-3.6 and 18-3.8 of this Subpart) for the taxable year by a fraction, the numerator of which is the eligible gross income of the IBF for the taxable year and the denominator of which is the gross income of the IBF for the taxable year.