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Noonan’s Notes Blog is written by a team of Hodgson Russ tax attorneys led by the blog’s namesake, Tim Noonan. Noonan’s Notes Blog regularly provides analysis of and commentary on developments in the world of New York tax law.

Despite the BCT being in place for over 10 years, it was only recently, on October 16, 2025, that the New York City Department of Finance (the “Department”) published the first set of proposed regulations for the BCT.  These proposed BCT regulations are largely based on the State’s regulations, but there are some significant differences concerning corporate limited partners which we will highlight below.

Just this week, the New York City Tax Appeals Tribunal Appeals Division upheld that decision, in Matter of A&E Television Networks, LLC, TAT(E) 20-32 (UB), handing the taxpayer a significant win—and hopefully curbing the City’s aggressive enforcement efforts more generally in UBT cases.  

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