Sec. 19-2.4. Allocation of entire net income on combined returns

Tax Law, § 1462(f)

In the case of combined returns, the factors comprising the entire net income allocation percentage are computed as though the corporations included in the return were one corporation. Intercorporate dividends and all other intercorporate transactions, including intercorporate receipts between the corporations included in the combined return, are eliminated. If one corporation included in the combined return makes the IBF election pursuant to section 19-2.3 of this Subpart, all corporations included in the combined return must make the same election. As to when combined returns will be required or permitted, see Subpart 21-2 of this Title.