Instructions for Form NYC-2.5A
Computation of  Receipts Factor of Combined Business Allocation Percentage                  2022
For tax years beginning on and after January 1, 2015, significant changes      use a minus (-) sign, not parentheses or brackets. 
were made to the rules for computing the receipts factor of the business        
allocation percentage. The receipts factor of the business allocation per-     For columns D and E, if any combined total for a particular line nets to 
centage under the Business Corporation Tax generally uses customer-            less than zero, enter  0for that line. Unless specifically instructed other-
based sourcing. Receipts from services are generally sourced to New            wise, enter in column D of any given line the result of row a, column A 
York City if the customer receives the benefit of the service in the City.     plus column B, minus column C for that particular line; and enter in col-
                                                                               umn E of any given line the result of row b, column A plus column B, 
In general, for tax years beginning in or after 2018, taxpayer combined        minus column C for that particular line. 
groups which allocate business income and business capital inside and out-      
side New York City must do so using their receipts factor (i.e. the per-       The column A, NYC receipts amounts for each line should be calculated 
centage of all receipts that are from sources inside New York City). See       using the applicable allocation  rule or fraction as computed for the com-
Administrative Code of the City of New York (“Administrative Code”)            bined group for each line. 
sections 11-654(3)(a)(10)(x) and 11-654.2. However, a combined group            
                                                                               Example:
with NYC receipts of $50,000,000 or less that allocates business income                   For line 44, in column A, the designated agent would multi-
                                                                               ply its own separate amount of receipts from the conduct of a railroad 
and business capital may make a one-time election to allocate business in-
                                                                               business or a trucking business by a fraction, the numerator of which is 
come and business capital using the three-factor weighted formula appli-
                                                                               the total miles of the combined group within New York City and the de-
cable to the 2017 tax year. Such election may only be made during a 
                                                                               nominator of which is the total miles of the combined group within and 
corporations’ first taxable year commencing on or after January 1, 2018, 
                                                                               outside New York City. 
and shall remain in effect until revoked by the corporation.  See Adminis-      
trative Code sections 11-654(3)(a)(10)(xii) and 11-654(3)(a)(10)(ix). For      For column F, use Worksheet D of these instructions to compute the des-
more on this election, see the instructions for Form NYC-2A, Schedule F.       ignated agent’s New York City receipts for the fixed dollar minimum  tax 
 
Receipts, net income, net gains, and other items are sourced, and the          base.  The amounts calculated using Worksheet D should then be entered 
amounts allowed in the receipts factor are determined, pursuant to Ad. Code    on the form in Column F, on line a of the corresponding line number.  For 
§11-654.2.  Include only the receipts, net income, net gains, and other items  example, the amount of the sales of tangible personal property on line 1 
described in §11-654.2, that are earned in the regular course of business      of Worksheet D should be entered in column F on line 1a of the form. 
                                                                                
and included in your business income, determined without regard to the         A combined group that has no receipts required to be included in the de-
amount subtracted on Schedule B, line 23 of Form NYC-2A (Subtraction           nominator of the allocation factor has a zero receipts factor.  Examples in-
modification for qualified banks), and without regard to any amount that is    clude a combined group that owns property in New York City but has no 
determined to exceed the 8% limitation on gross investment income.             FTI, ECI, or receipts from the rental, sale or lease of such property 
 
Generally, receipts from services are reported on line 52, (Receipts from      amounts, or a combined group whose only income is dividends and net 
other services/activities not specified).                                      gains from the sales of stock or sales of partnership interests when the 
                                                                               fixed percentage election is not made.  If you have a denominator of zero, 
In determining the receipts  factor of the business allocation percentage  for you must attach a statement explaining why you have no receipts required 
a combined return, the receipts, net income, net gains, and other  items of    to be included in the receipts  factor of the business allocation percentage. 
all the members of the combined group, whether or not they are taxpayers,       
are included; and intercorporate receipts, income, and gains are eliminated.   SECTION 11-654.2(2) – SALES OF TANGIBLE PERSONAL PROP-
                                                                               ERTY, ELECTRICITY AND NET GAINS FROM REAL PROPERTY 
New York City (NYC) amounts to enter in    row a of Form NYC-2.5A,              
lines 1 through 53 are determined per the specific line instructions below.    Line 1 – Receipts from the sale of tangible personal property are allo-
Everywhere (EW) amounts to enter in       row b of Form 2.5A, lines 1          cated to New York City when shipments are made to points in the City, 
through 53 should be 100%, before intercorporate eliminations, of the          or the destination of the property is a point in the City. Receipts from 
amount of the item being reported on a line, unless otherwise specified.       sales of tangible personal property and electricity that are traded as com-
If only one line of this form applies to your business, you must still enter   modities, as defined in IRC section 475, are included on line 27, in ac-
the NYC and EW amounts for that line. Skip a line only if both the nu-         cordance with §11-654.2(5)(a)(2)(ix). 
merator (NYC) and the denominator (EW) are zero.                                
                                                                               Line 2 – Receipts from the sale of electricity are allocated to New York 
For columns A (designated agent) and B, for all lines involving the com-       City when delivered to points in the City. Receipts from sales of tangi-
putation of net gains, net income, or net interest, amounts less than zero     ble personal property and electricity that are traded as commodities, as 
must be entered, where applicable. Amounts less than zero are allowed          defined in IRC section 475, are included on line 27, in accordance with 
in columns A and B because these amounts must be netted on a com-              §11-654.2(5)(a)(2)(ix). 
bined basis in columns D and E to amounts not less than zero for each           
such line. For columns A and B use a minus sign (-) to report amounts          Line 3 – For the NYC row, net the gains from the sales of real property 
less than zero (not parentheses or brackets).                                  located within the city against the losses from the sales of real property 
                                                                               located within the city and enter the result (but not less than zero). For 
Form NYC-2.5A/BC must be completed for all        group members (in-           the EW row, net the gains from the sales of real property located every-
cluding non-NYC taxpayers),      except for the group designated agent.        where against the losses from the sales of real property located every-
For column  B(Total of all Affiliates) the amount to include in rows a         where and enter the result (but not less than zero). 
and b of such column for  any specific group member, except for the des-        
ignated agent, comes from such group member’s Form NYC-2.5A/BC,                SECTION 11-654.2(3) – RENTALS OF REAL AND TANGIBLE 
columns A and B.                                                               PERSONAL PROPERTY, ROYALTIES, AND RIGHTS FOR CER-
                                                                               TAIN CLOSED-CIRCUIT AND CABLE TV TRANSMISSIONS                         
For column C, the amount entered can be either a positive or negative           
amount depending on what is being eliminated. If a negative amount,            Line 4 – Receipts from rentals of real and tangible personal property lo-

 Instructions for Form NYC-2.5A - 2022                                                                                                           Page 2

cated within the City are allocated to New York City.                                  (reported on lines 22-24); Type (ix) (reported on line 27); Type(s) (viii) (re-
                                                                                       ported on lines 29 and 30); and Type(s) (vii) (also reported on line 30). 
Line 5 – Receipts of royalties from the use of patents, copyrights, trade-             If the taxpayer has in the tax year marked to market a financial instru-
marks, and similar intangible personal property within the City are in-                ment within types (i),(ii),(iii), (iv)and (ix), then any financial instrument 
cluded in the New York City row.                                                       within that same type that has      not been marked to market by the tax-
                                                                                       payer under IRC section 475 or 1256 is also a QFI in the tax year.  When 
Line 6 – Receipts from the sales of rights for closed-circuit and cable tel-           a financial instrument within either  Types (viii) or (vii) is marked to 
evision transmissions of an event (other than events occurring on a reg-               market, not all financial instruments within type (viii) or (vii), respec-
ularly scheduled basis) taking place within the City as a result of the                tively are QFIs, as explained further below. 
rendition of services by employees of the corporation, as athletes, enter-              
tainers or performing artists, are entered in the New York City row to                 When reporting interest from “other” financial instruments on line 29, 
the extent that those receipts are attributable to such transmissions re-              and net gains and other income from “other” financial instruments on 
ceived or exhibited within the City.                                                   line 30, marking to market one “other” financial instrument does      not       
 
SECTION 11-654.2(4) – RECEIPTS FROM SALE OF, LICENSE                                   necessarily cause all “other” financial instruments to be QFIs.  It is an in-
TO USE, OR GRANTING OF REMOTE ACCESS TO DIGITAL                                        strument by instrument determination as to when “other “ financial in-
PRODUCTS                                                                               struments are of the same type.  Thus, you may have more than one type 
                                                                                       of “other” financial instruments reported on lines 29 and 30 , and some 
Line 7 – For purposes of allocation under Subchapter 3-A of Chapter 6                  types may be QFI while some other types may not be QFI. 
of Title 11 of the Ad. Code (“Subchapter 3-A”), the term digital product                
means any property or service, or combination thereof, of whatever nature              Line 30 can be used to report financial instruments under clause (vii) (div-
delivered to the purchaser through the use of wire, cable, fiber optic, laser,         idends and net gains from sales of stock or partnership interests)  orclause 
microwave, radio wave, satellite or similar successor media, or any com-               (viii) (“other” financial instruments) of §11-654.2(5)(a)(2), or both.  Line 30 
bination of these. Digital product includes, but is not limited to, an audio           will be used to report instruments under clause (vii) only when the finan-
work, audiovisual work, visual work, book or literary work, graphic work,              cial instrument is a QFI and the 8% fixed percentage method had been 
game, information or entertainment service, storage of digital products.  In           elected.  When any stock that is business capital has been marked to mar-
addition, it includes computer software by whatever means delivered.                   ket, all stock that is business capital is a QFI (for exception see next para-
The term delivered to includes furnished or provided to or accessed by. A              graph immediately following).  When any partnership interest in a widely 
digital product doesnot include legal, medical, accounting, architectural,             held or publicly traded partnership has been marked to market,  allpartner-
research, analytical, engineering or consulting services.                              ship interests in a widely held or publicly traded partnership are QFIs.  
                                                                                       However, marking to market stock that is business capital does not cause 
If the receipt for a digital product is comprised of a combination of digital prop-    partnership interests in a widely held or publicly traded partnership that are 
erty and services, it cannot be divided into separate components and is considered     not marked to market to be QFIs. The same is true in regard to the mark-
to be one receipt, regardless of whether it is separately stated for billing purposes. ing to market of partnership interests in a widely held or publicly  traded 
The entire receipt must be allocated according to a hierarchy (see below).             partnership in respect to stock that is business capital.  When a financial in-
 
                                                                                       strument falling under clause (viii) has been market to market, it does not 
Receipts from the sale of, license to use, or granting of remote access to 
                                                                                       necessarily cause all financial instrument s under clause (viii) to be QFIs.  
digital products within the City, are sourced by each corporation in the 
                                                                                       It is an instrument by instrument determination as to when instruments 
combined group according to the following hierarchy: 
                                                                                       under clause (viii) are of the same type.  Thus, you may have more than one 
1) The customer’s primary use location of the digital product.                         type of “other” financial instruments under clause (viii) to report on line 
                                                                                       30.  Marking to market a financial instrument of the type under clause (vii) 
2) The location where the digital product is received by the customer                  does not cause financial instrument of the type under clause (viii) to be 
   or is received by a person designated for receipt by the customer.                  QFIs.  The same is true in regard to clause (viii) in respect to clause (vii).   
 
3) The receipts fraction determined pursuant to Administrative Code 
                                                                                       If the only loans that are marked to market under IRC section 475 or 
   §11-654.2(4) of the taxpayer for the preceding tax year for such 
                                                                                       1256 are loans secured by real property, then no loans are QFIs. Stock 
   digital product. 
                                                                                       that is investment capital shall not be a QFI. A stock that generates other 
4) The receipts fraction in the current tax year for those digital prod-               exempt income as defined in section 11-652(5-a) and that is not, itself, 
   ucts that can be sourced using the methods in items 1 and 2.                        marked to market under section 475 or section 1256 of the IRC, is not a 
                                                                                       QFI with respect to such other exempt income only, even if other stocks 
Note: Item 3 does not apply to your first tax period that begins on or                 are marked to market in the tax year. 
after January 1, 2015, for which you are subject to Subchapter 3-A.                     
 
Each corporation in the combined group must exercise due diligence                     Taxpayers may elect to use the 8% fixed percentage method to allocate 
under each method before rejecting it and proceeding to the next method                business receipts from QFIs. This election is irrevocable, applies to all 
in the hierarchy, and must base its determination on information known                 QFIs, and must be made on an annual basis on the original timely filed 
to the taxpayer or information that would be known to the taxpayer upon                return (determined with regard to valid extensions of time for filing) by 
reasonable inquiry.                                                                    checking the YES box on line 8. If you check the NO box or do not check 
                                                                                       either box but still allocate QFIs receipts by 8%, you will be considered 
SECTION 11-654.2(5)(a)(1) – QUALIFIED FINANCIAL INSTRU-                                to have made the election and to have checked the YES box.   
MENTS (QFIs), THE 8% METHOD                                                             
                                                                                       Regardless of whether or not the 8% fixed percentage method is elected, 
Line 8 – A qualified financial instrument (QFI) means a financial instru-              when   any financial instrument has been marked to market that is de-
ment of these types that is marked to market in the tax year by the taxpayer           scribed on: 
under IRC section 475 or 1256: Type (i) (reported on lines 11 and 12); Type             
(ii) (reported on lines 13-18); Type (iii) reported on lines 19-21; Type (iv)          a) either line 11 or 12, then the boxes on both lines 11 and 12 must be 

 Instructions for Form NYC-2.5A - 2022                                                                                                        Page 3

   marked; and all financial instruments reported on such lines are QFIs         or dealer means a broker or dealer registered as such by the Securities 
   (Type (i) financial instruments);                                             and Exchange Commission (SEC) or a broker or dealer registered as 
                                                                                 such by the Commodities Futures Trading Commission, and shall in-
b) any of lines 13 through 18, then the box above line 13 must be                clude an over-the-counter (OTC) derivatives dealer as defined under reg-
   marked and all financial instruments reports on such lines are QFIs           ulations of the SEC (17 CFR 240.3b-12). 
   (Type (ii) financial instruments);                                             
 
c) any of lines 19 through 21, then the box above line 19 must be                SECTION 11-654.2(5)(a)(2)(i) – LOANS 
                                                                                  
   marked, and all financial instruments reported on such lines are QFIs         A loan is secured by real property if 50% or more of the value of the col-
   (Type (iii) financial instruments);                                           lateral used to secure the loan (when valued at FMV as of the time the 
 
d) any of lines 22 through 24, then the box above line 22 must be                loan was originated) consists of real property. 
   marked and all financial instruments reported on such lines are QFIs           
   (Type (iv) financial instruments);                                            Line 9 – Include in the New York City row, interest from loans secured 
                                                                                 by real property located within the City.  Include in the EW row interest 
e) line 27, then the box above line 27 must be marked, and all financial         from loans secured by real property located anywhere. 
   instruments reported on line 27 are QFIs (Type (ix) financial instru-          
   ments);                                                                       Line 10 – The New York City amounts are determined  by multiplying the 
                                                                                 amount of net gains  from sales of loans secured by real property by a fraction, 
f) Line 28, then the box above line 28 must be marked;                           the numerator of which is the amount of gross proceeds from sales of loans se-
 
                                                                                 cured by real property located within the City, and the denominator of which 
g) Line 29, then the Section 11-654.2(5)(a)(2)(viii) box above line 29 
                                                                                 is the amount of gross proceeds from sales of such loans everywhere.  Gross 
   must be marked; 
                                                                                 proceeds are determined after the deduction of any cost to acquire the loans, 
h) Line 30, due to clause (viii), then Section 11-654.2(5)(a)(2)(viii) box       but shall not be less than zero.  EW amounts are the amount of net gains  from 
   above line 30 must be marked; and                                             sales of loans secured by real property both within and outside New York City. 
                                                                                  
i) Line 30, due to clause (vii), then the section 11-654.2(5)(a)(2)(vii)         Use Worksheet A at the end of these instructions. 
   box above line 30 must be marked.                                              
                                                                                 Line 11 – If the fixed percentage method election has been made (the box 
A marked QFI box does not indicate which method of sourcing (8% fixed            on line 8 is marked), and the QFI box above line 11 is marked, enter 8% 
percentage method or customer-based sourcing rule) is being used to allo-        of the applicable receipts in row a, columns A and B. 
cate such instruments.  Also, because lines 28, 29, and 30 may report more        
than one type of financial instrument when the QFI box above line 28 is          When the 8% fixed percentage method is not elected (the box on line 8 
marked or one of the boxes above lines 29 and 30 is marked: a) in the case       is not marked), and the QFI box above line 11  ismarked, use the cus-
of line 28 it does not indicate that all financial instruments being reported on tomer-based sourcing rule below for all financial instruments to be re-
line 28 are QFIs,  and b) in the case of lines 29 and 30 it does not indicate    ported on this line. 
that all financial instruments being reported on  line 29 or line 30 are QFIs.    
                                                                                 When the QFI box above line 11 is not marked, use the customer-based 
General lines 9 through 52 instructions                                          sourcing rule below for all financial instruments to be reported on this 
                                                                                 line. 
For all financial instruments that do not meet the definition of a QFI, or        
for instruments that meet the definition of a QFI but the 8% fixed per-          In the NYC row, include interest from loans not secured by real property 
centage method election is not in effect, use the customer-based sourc-          if the borrower is located in New York City. 
ing rules as provided in the individual line instructions for lines 9 through     
27, 29, and 30.                                                                  In the EW row, include interest from all loans not secured by real prop-
                                                                                 erty. 
Regardless of whether or not the 8% fixed percentage method election is           
in effect, Worksheets A, B, and C of these instructions compute certain          Line 12 – New York City amounts are determined by multiplying net gains 
amounts for lines 10, 12, 21, 24, 28, and 30 of: Form NYC-2.5A, Form             from sales of loans not secured by real property by a fraction, the numerator 
NYC-2.5A/BC, and Worksheet D of these instructions.                              of which is the amount of gross proceeds from sales of loans not secured by 
 
For purposes of these allocation instructions, an individual is deemed to        real property to purchasers located within the City, and the denominator of 
be located in New York City if his or her billing address is in the City. A      which is the amount of gross proceeds from sales of such loans to purchasers 
business entity is deemed to be located in New York City if its commer-          located within and outside the City.  Gross proceeds are determined after the 
cial domicile is located in the City.                                            deduction of any cost to acquire the loans, but shall not be less than zero.  
                                                                                  
Use the following hierarchy to determine the commercial domicile of a            EW amounts are  the amount of net gains from sales of loans not secured 
business entity, based on known information, or information that would           by real property within and outside the City. 
be known upon reasonable inquiry:                                                 
                                                                                 Use Worksheet A at the end of these instructions. 
1) The seat of management and control of the business entity.                     
                                                                                 SECTION 11-654.2(5)(a)(2)(ii) – FEDERAL, STATE, AND MU-
2) The billing address of the business entity in the taxpayer’s records.         NICIPAL DEBT 
                                                                                  
You must exercise due diligence before rejecting the first method and            For lines 13 and 15: 
proceeding to the next method in this hierarchy.                                  
For purposes of these allocation instructions, registered securities broker      •      If the 8% fixed percentage method election has been made (the box 

 Instructions for Form NYC-2.5A - 2022                                                                                                    Page 4

   on line 8 is marked), and the QFI box above line 13 is marked, enter      2)  Sales of other asset-backed securities that are sold through a regis-
   8% of the applicable receipts in row a, columns A and B. Enter                tered securities broker or dealer, or through a licensed exchange. 
   100% of the applicable receipts in row b, columns A and B.                 
                                                                             In the NYC row, enter 8% of the amount in the EW row 
•  In all other instances, enter  0in row a, columns A, B, C, and D.          
   Enter 100% of the applicable receipts in row b, columns A and B.          Line 21 – For the New York City amount, multiply net gains from sales 
                                                                             of other asset-backed securities not reported on line 20 by a fraction, the 
For line 16:                                                                 numerator of which is the amount of gross proceeds from such sales to 
                                                                             purchasers located in the City and the denominator of which is the amount 
•  If the 8% fixed percentage method election has been made (the box         of gross proceeds from such sales to purchasers located within and out-
   on line 8 is marked), and the QFI box above line 13 is marked, enter      side the City.  Gross proceeds are determined after the deduction of any 
   8% of the applicable receipts in row a, columns A and B.  Enter           cost incurred to acquire the securities, but shall not be less than zero. 
   100% of the applicable receipts in row b, columns A and B.                 
                                                                             The EW is 100% of the amount of net gains (not less than zero) from 
•  In all other instances, enter  0in row a, columns A, B, C, and D.         sales of other asset-backed securities not reported on line 20. 
   Enter 100% of the applicable receipts in row b, columns A and B.           
   For row b, column E, add row b, column A to row b, column B;              Use Worksheet A at the end of these instructions. 
   then subtract row b, column C and enter the result.  If the result is      
   less than zero, enter  0in column E.                                      SECTION 11-654.2(5)(a)(2)(iv) – CORPORATE BONDS 
                                                                              
For line 17:                                                                 Line 22 – In the New York City row, enter interest from corporate bonds 
                                                                             when the commercial domicile of the issuing corporation is in the City. 
•  If the 8% fixed percentage method election has been made (the box          
                                                                             If the 8% fixed percentage method election has been made (the box on 
   on line 8 is marked), and the QFI box above line 13 is marked, enter      line 8 is marked), and the QFI box above line 22 is marked, enter 8% of 
   8% of the applicable receipts in row a, columns A and B. Enter            the applicable receipts in row a, columns A and B. 
   100% of the applicable receipts in row b, columns A and B.                 
                                                                             Line 23 – For the EW row, enter the result (but not less than zero) of 
•  In all other instances, enter  0in row a, columns A, B, C, and D.         netting the gains and losses from the sales of all corporate bonds through 
   Enter only 50% (not 100%) of the applicable everywhere receipts           a licensed exchange, or through a registered securities broker or dealer. 
   in row b, columns A and B.                                                For the NYC row, enter 8% of the amount in the EW row. 
                                                                              
For line 18:                                                                 Line 24 – For the New York City amount, net gains from those sales of 
                                                                             corporate bonds not reported on line 23 is multiplied by a fraction, the nu-
•  If the 8% fixed percentage method election has been made (the box         merator of which is the amount of gross proceeds from such sales to pur-
   on line 8 is marked), and the QFI box above line 13 is marked, enter      chasers located within the City, and the denominator of which is the 
   8% of the applicable receipts in row a, columns A and B.  Enter           amount of gross proceeds from such sales to purchasers located within and 
   100% of the applicable receipts in row b, columns A and B.                outside the City.  Gross proceeds are determined after the deduction of any 
                                                                             cost incurred to acquire the securities, but shall not be less than zero. 
•  In all other instances, enter  0in row a, columns A, B, C, and D.          
   Enter 100% of the applicable receipts in row b, columns A and B.          The EW  amount is the amount of net gains from sales of corporate bonds 
   For row b, column E, add row b, column A to row b, column B;              not reported on line 23 to purchasers within and outside the City. 
   then subtract row b, column C and enter the result. If the result is       
   less than zero, enter  0in column E.  If the result is greater than zero, Use Worksheet A at the end of these instructions. 
   multiply the result by 50% and enter the result in column E.               
                                                                             SECTION 11-654.2(5)(a)(2)(v) – INTEREST INCOME FROM RE-
SECTION 11-654.2(5)(a)(2)(iii) – ASSET-BACKED SECURITIES AND                 VERSE REPURCHASE  AND SECURITIES BORROWING 
OTHER GOVERNMENT AGENCY DEBT                                                 AGREEMENTS 
                                                                              
Line 19 – In the EW row, enter 100% of the interest income from all:         Line 25 – In column E enter the combined group’s net interest income 
                                                                             (not less than zero), and after intercorporate eliminations, from reverse 
1) Asset-backed securities issued by government agencies;                    repurchase agreements and securities borrowing agreements. For this cal-
                                                                             culation, the combined group’s net interest income is determined after the 
2) Other securities issued by government agencies, including but not         deduction of the amount of the combined group’s interest expense, after 
   limited to securities issued by the Government National Mortgage          intercorporate eliminations, from repurchase agreements and securities 
   Association (GNMA), the Federal National Mortgage Association             lending agreements, but cannot be less than zero. The amount of the com-
   (FNMA), the Federal Home Loan Mortgage Corporation                        bined group’s interest expense to be deducted is the combined group’s in-
   (FHLMC), or the Small Business Administration (SBA); and                  terest expense associated with the sum, determined after intercorporate 
                                                                             eliminations, of the value of the combined group’s repurchase agreements 
3) Asset-backed securities issued by other entities.                         where a member of the combined group is the seller or borrower,    plus 
                                                                             the value of the combined group’s securities lending agreements where a 
In the NYC row, enter 8% of the amount in the EW row.                        member of the combined group is the securities lender; provided that such 
Line 20 – In the EW row, enter the result (but not less than zero) of net-   sum is limited to the sum, after intercorporate eliminations, of the value 
ting the gains and losses from all:                                          of the combined group’s reverse repurchase agreements where a member 
 
1) Sales of asset-backed securities or other securities issued by gov-       of the combined group is the purchaser or lender, plus the value of the 
   ernment agencies, including but not limited to securities issued by       combined group’s securities borrowing agreements where a member of 
   GNMA, FNMA, FHLMC, or the SBA; and                                        the combined group is the securities borrower. 

 Instructions for Form NYC-2.5A - 2022                                                                                                   Page 5

In column D, enter 8% of the amount in column E.                            net gains from actual sales of that type of financial instrument deter-
                                                                            mined on the applicable line. 
SECTION 11-654.2(5)(a)(2)(vi) – INTEREST INCOME FROM                         
FEDERAL FUNDS                                                               For the EW amount, use 100% of the marked to market net gains from 
                                                                            financial instruments for which the amount to be included in the New 
Line 26 -  In the EW row, enter 100% of the net interest from federal       York City row is determined under the immediately preceding paragraph. 
funds. In determining net interest from federal funds, deduct interest ex-   
pense that is from federal funds. The resulting net interest cannot be less SECTION 11-654.2(5)(a)(2)(x)(C) 
than zero.                                                                   
                                                                            If the type of financial instrument that is marked to market is not otherwise 
In the NYC row, enter 8% of the amount in the EW row.                       sourced by the taxpayer on lines 9 through 30,  orif the taxpayer has a net 
                                                                            loss from the sales of that type of financial instrument not otherwise sourced 
SECTION 11-654.2(5)(a)(2)(ix) – NET INCOME FROM SALES OF                    on lines 9 through 30, for the New York City row, multiply the marked to 
PHYSICAL COMMODITIES                                                        market net gains from that type of financial instrument by a fraction, the nu-
                                                                            merator of which is the sum of the amount of receipts  from financial in-
Line 27 –  For the New York City amount, multiply the net income            struments entered in the New York City row on lines 9 through 30, plus 
from sales of physical commodities by a fraction, the numerator of          any New York City receipts determined under §11-654.2(5)(a)(2)(x)(B)  
which is the amount of receipts from sales of physical commodities          above, and any amount included in the New York City row on line 53 under 
actually delivered to points within the City or, if there is no actual de-  §11-654.2(5)(a)(2)(vii), and the denominator of which is the sum of the 
livery of the physical commodity, the amount sold to purchasers lo-         amount of receipts entered in the EW row on lines 9 through 30, plus any 
cated in the City, and the denominator of which is the amount of            everywhere receipts determined under §11-654.2(5)(a)(2)(x)(B) above. 
receipts from all sales of physical commodities actually delivered to        
points within and outside the City or, if there is no actual delivery of    For the EW amount, use 100% of the marked to market net gains from fi-
the physical commodity, the amount sold to purchasers located both          nancial instruments for which the amount to be included in the New York 
within and outside the City.                                                City row is determined under the immediately preceding paragraph.  
                                                                             
For the EW amount, use 100% of the net income from sales of physical        Use Worksheet C at the end of these instructions. 
                                                                             
commodities.                                                                However, when sourcing the marked to market net gain from loans se-
 
For this line, net income is determined after the deduction of the cost to  cured by real property, always use customer-based sourcing (even when 
acquire or produce the physical commodities.                                the 8% fixed percentage method election was made). If using customer-
                                                                            based sourcing to source such marked to market  net gains,  when sec-
If the fixed percentage method election has been made (the box on line      tion 11-654.2(5)(a)(2)(x)(C) applies, never include any amounts sourced 
8 is marked), and the QFI box above line 27 is marked, enter 8% of the      under the 8% fixed percentage method election in computing the NYC 
applicable receipts in row a, columns A and B.                              aggregate MTM factor in Part 2 of Worksheet C. 
                                                                             
SECTION 11-654.2(5)(a)(2)(x) – MARKED TO MARKET NET                         SECTION 11-654.2(5)(a)(2)(viii) – INCOME FROM OTHER FI-
GAINS                                                                       NANCIAL INSTRUMENTS 
                                                                             
Line 28 – All  marked to market net gains are reported on this line for     Line 29 – When the 8% fixed percentage method  iselected, use such 
all financial instruments. For purposes of computing marked to mar-         method for all financial instruments to be reported on this line that are 
ket net gains for this line, marked to market (MTM) means that a fi-        QFIs. When the 8% fixed percentage method   elected,is   use the cus-
nancial instrument is treated by the taxpayer as sold for its FMV on        tomer-based sourcing rule below for those financial instruments to be 
the last business day of the taxpayer’s tax year, despite no actual sale    reported on this line that are  not QFIs. Also, use the customer-based 
having taken place, under IRC sections 475 or 1256. The term marked         sourcing rule below for all financial instruments to be reported on this 
to market (MTM) gain or loss means the gain or loss recognized by the       line when the 8% fixed percentage method is not elected. 
                                                                             
taxpayer under IRC sections 475 or 1256 because the financial in-
                                                                            In the New York City row, enter interest from other financial instruments 
strument is treated as sold for its FMV on the last business day of the 
                                                                            when the payor is located in New York City. 
tax year.                                                                    
                                                                            Line 30 – More than one type of financial instrument may be reported 
All MTM net gains are reported on this line. When the 8% fixed per-         on this line. Report financial instruments under clause (vii) or clause 
centage method  iselected, use such method  for all QFIs. When the 8%       (viii) of §11-654.2(5)(a)(2). 
fixed percentage method  iselected, use the following instructions to        
source MTM net gains that are not QFIs. When the 8% fixed percentage         Include clause (vii) financial instruments only when the 8% fixed per-
method isnot elected,all MTM net gains are sourced using the follow-        centage method  iselected. The following constitute clause (vii) instru-
ing instructions.                                                           ments to be included:  
                                                                             
SECTION 11-654.2(5)(a)(2)(x)(B)                                             • dividends and net gains from stock that is business capital if you have, 
                                                                             in the tax year, marked to market any stock under IRC section 475 or 
The amount of marked to market net gains from each type of financial         1256; provided that dividends that qualify as other exempt income 
instrument to be included in the New York City row is determined by          should not be included; and  
multiplying such net gains from each such type of financial instrument       
by a fraction, the numerator of which is the numerator of the receipts      • net gains from the sale of partnership interests in widely held or pub-
fraction for the net gains from actual sales of that type of financial in-   licly traded partnerships if you have, in the tax year, marked to mar-
strument as reported on lines 9 through 30 (as applicable), and the de-      ket any partnership interest in a widely held or publicly traded 
nominator of which is the denominator of the receipts fraction for the       partnership under IRC section 475 or 1256. 

 Instructions for Form NYC-2.5A - 2022                                                                                                         Page 6

Customer-based sourcing rules for clause (viii) instruments included on            rities being marketed and the price received from the subsequent sale of 
line 30:                                                                           the underwritten securities at the initial public offering price, less any 
• for gains from “other” financial instruments, for the EW row, net the            selling concession and any fees paid to the taxpayer for advisory services 
 gains from all sales of a type of “other” financial instrument against the        or any manager’s fees, if those fees are not paid by the customer to the 
 losses from all sales of the same type of “other” financial instrument.           taxpayer separately. The term   public offering price means the price 
 For the NYC row, for the     same type of “other” financial instrument            agreed upon by the taxpayer and the issuer at which the securities are to 
 being reported in the EW row, net the gains from all sales of such same           be offered to the public. The term selling concession means the amount 
 type of “other” financial instrument, where the purchaser or payor is lo-         paid to the taxpayer for participating in the underwriting of a security 
 cated in New York City, against the losses from all sales of such same            where the taxpayer is not the lead underwriter. 
 type of “other” financial instrument, where the purchaser or payor is lo-          
 cated in New York City. However, if the purchaser or payor is a regis-            Line 35 – In the New York City row, enter account maintenance fees if 
 tered securities broker or dealer, or the transaction is made through a           in the records of the taxpayer, the mailing address of the customer re-
 licensed exchange, then include 8% of the EW amount in the NYC row.               sponsible for paying such account maintenance fees is in the City. 
                                                                                    
• for “other” income from “other” financial instruments, for the EW                Line 36 – In the New York City row, enter fees for management or ad-
 row, compute the “other” income (but not less than zero) from a type              visory services, including fees for advisory services in relation to merger 
 of “other” financial instrument. For the NYC row, for the same type               or acquisition activities, if in the records of the taxpayer, the mailing ad-
 of “other” financial instrument being reported in the EW row, compute             dress of the customer responsible for paying such fees is in the City. Ex-
 the “other” income (but not less than zero) from such same type of                clude fees paid for services reported on line 43. 
                                                                                    
 “other” financial instrument, where the purchaser or payor is located             Line 37 – Interest earned on loans and advances made by the taxpayer 
 in New York City. However, if the purchaser or payor is a registered              to a corporation affiliated with the taxpayer, but with which the taxpayer 
 securities broker or dealer, or the transaction is made through a li-             is not included in a combined return under Subchapter 3-A of Chapter 6 
 censed exchange, then include 8% of the EW amount in the NYC row.                 of Title 11 of the Administrative Code are deemed to arise from services 
 
Use Worksheet B at the end of these instructions.                                  performed at the principal place of business of the affiliated corporation. 
                                                                                   If such principal place of business is in New York City, include the in-
SECTION 11-654.2(5)(b) – OTHER RECEIPTS FROM BROKER                                terest in the New York City row. 
OR DEALER ACTIVITIES                                                                
                                                                                   SECTION 11-654.2(5)(c) – RECEIPTS FROM CREDIT CARD 
For the purposes of lines 31 through 37, securities has the same meaning as        AND SIMILAR ACTIVITIES 
in IRC section 475(c)(2), and commodities has the same meaning as in IRC            
section 475(e)(2). If the taxpayer receives any of the receipts reported on lines  Lines 38 through 42 – These lines are used by corporations that issue 
31 through 35 as a result of a securities correspondent relationship that the tax- or process credit cards and not by businesses that accept credit cards as 
payer has with another broker or dealer (with the taxpayer acting in this rela-    payment for goods or services.  
tionship as the clearing firm), those receipts are deemed generated within the      
City to the extent set forth in §11-654.2(5)(b)(1) through §11-654.2(5)(b)(4).     Line 38 – In the New York City row, enter interest, fees, and penalties 
The amount of those receipts excludes the amount the taxpayer is required to       in the nature of interest from bank, credit, travel, and entertainment card 
pay to the correspondent firm for the correspondent relationship. If the tax-      receivables if in the records of the taxpayer, the mailing address of the 
payer receives any of the receipts reported on lines 31 through 35 as a result     card holder is in the City. 
of a securities correspondent relationship that the taxpayer has with another       
broker or dealer (with the taxpayer acting in this relationship as the introduc-   Line 39 – In the New York City row, enter service charges and fees from 
ing firm), these receipts are deemed generated within the City to the extent set   such cards, if in the records of the taxpayer, the mailing address of the 
forth in §11-654.2(5)(b)(1) through §11-654.2(5)(b)(4). If the taxpayer is un-     card holder is in the City. 
                                                                                    
able to determine the mailing address of the customer from its records, include    Line 40 – In the New York City row, enter receipts from merchant dis-
8% of the receipts in the numerator of the allocation fraction.                    counts when the merchant is located within the City. If the merchant has 
 
Line 31 – In the New York City row, enter brokerage commissions derived            locations both within and outside of New York City, only receipts from 
from the execution of securities or commodities purchase or sales orders for       merchant discounts attributable to sales made from locations within New 
the accounts of customers if in the records of the taxpayer, the mailing ad-       York City are entered in the New York City row. The location of the mer-
dress of the customer responsible for paying the commissions is in the City.       chant is presumed to be the address of the merchant shown on the in-
                                                                                   voice submitted to the taxpayer by the merchant. 
Line 32 – In the New York City row, enter margin interest earned on behalf          
of brokerage accounts if in the records of the taxpayer, the mailing address       Line 41 – In the New York City row, enter receipts from credit card author-
of the customer responsible for paying such margin interest is in the City.        ization processing, and clearing and settlement processing, received by credit 
                                                                                   card processors if the location where the customer of the credit card proces-
Line 33 – In the New York City row, enter the amount of fees for advisory          sor accesses the credit card processor’s network is located within the City. 
services to a customer in connection with the underwriting of securities            
for the entity that is contemplating issuing or is issuing securities, or fees     Line 42 – For the New York City row, multiply the total amount of all 
for managing an underwriting, if in the records of the taxpayer, the mail-         other receipts received by credit card processors not reported on lines 1 
ing address of the customer responsible for paying such fees is in the City.       through 53c by the average of 8% and the percent of its New York City 
                                                                                   access points. The percent of New York City access points is the number 
Line 34 – In the New York City row, enter the receipts constituting the            of locations within New York City from which the credit card processor’s 
primary spread of selling concession from underwritten securities if the           customers access the credit card processor’s network, divided by the total 
customer is located in the City. The term primary spread means the dif-            number of locations in the United States where the credit card proces-
ference between the price paid by the taxpayer to the issuer of the secu-          sor’s customers access the credit card processor’s network. 
                                                                                    

 Instructions for Form NYC-2.5A - 2022                                                                                                                                                                                    Page 7

SECTION 11-654.2(5)(d) – RECEIPTS FROM CERTAIN SERVICES                                                                         service of selling such shares. In the case of an open-end company, 
TO INVESTMENT COMPANIES                                                                                                         the service of selling shares must be performed pursuant to a con-
                                                                                                                                tract entered into pursuant to the federal Investment Company Act 
Line 43 – For the New York City row, multiply the receipts received                                                             of 1940, section 15(b), as amended. 
from an investment company arising from the sale of management, ad-             
ministration, or distribution services to such investment company by a         •                                                Administration services includes clerical, accounting, bookkeep-
fraction, the numerator of which is the sum of the monthly percentages                                                          ing, data processing, internal auditing, legal, and tax services per-
determined for each month of the investment company’s federal tax year                                                          formed for an investment company, but only if the provider of such 
that ends within the tax year of the taxpayer (but excluding any month                                                          service or services during the tax year in which such service or serv-
during which the investment company had no outstanding shares), and                                                             ices are sold also sells management or distribution services (as de-
the denominator of which is the number of those monthly percentages.                                                            fined above), to such investment company. 
                                                                                
To determine the monthly percentage for each month, divide the number          SECTION 11-654.2(6) – RECEIPTS FROM RAILROAD  AND 
of shares in the investment company that are owned on the last day of the      TRUCKING BUSINESSES 
month by shareholders that are located in New York City by the total            
number of shares in the investment company outstanding on that date.           Line 44 –                                         For the New York City row, multiply receipts from the con-
                                                                               duct of a railroad business or a trucking business (including surface rail-
In the EW row, enter 100% of the receipts received from an investment          road, whether or not operated by steam, subway railroad, elevated 
company arising from the sale of management, administration, or distri-        railroad, palace car or sleeping car business) by a fraction, the numera-
bution services to the investment company.                                     tor of which is the miles in such business within the City during the pe-
                                                                               riod covered by this return, and the denominator of which is the miles in 
For purposes of these receipts, the following apply:                           such business both within and outside the City during such period. 
 
•   An individual, estate or trust is deemed located in New York City           
    if his, her, or its mailing address in the records of the investment       SECTION 11-654.2(12) – RECEIPTS FROM OPERATION OF 
    company is in the City. A business entity is deemed located in New         VESSELS 
    York City if its commercial domicile is located in the City.                
                                                                               Line 45 – For the New York City row multiply receipts from the opera-
•   Investment company means a regulated investment company, as defined        tion of vessels by a fraction, the numerator of which is the aggregate 
    in IRC section 851, and a partnership to which IRC section 7704(a) ap-     number of working days of the vessels owned or leased by the taxpayer 
    plies (by virtue of section 7704(c)(3)) and that meets the requirements    in territorial waters of the City during the period covered by this return, 
    of IRC section 851(b). This is applied to the tax year, for federal income and the denominator of which is the aggregate number of working days 
    tax purposes, of the business entity that is asserted to constitute an in- of all vessels owned or leased by the taxpayer during such period. 
    vestment company that ends within the tax year of the taxpayer.             
 
                                                                               SECTION 11-654.2(7) – RECEIPTS FROM AVIATION SERVICES 
•   Receipts from an investment company includes amounts received di-           
    rectly from an investment company as well as amounts received from         Line 46 –                                         Air freight forwarding – In the New York City row, enter the 
    the shareholders in the investment company, in their capacity as such.     receipts from the activity of air freight forwarding acting as principal and 
 
•   Management services means the rendering of investment advice to            like indirect air carrier receipts arising from that activity as follows: 
                                                                                
    an investment company, making determinations as to when sales and          •                                                100% of such receipts if both the pickup and delivery associated with 
    purchases of securities are to be made on behalf of an investment                                                           those receipts are made in the City; and 
    company, or the selling or purchasing of securities constituting as-        
    sets of an investment company, and related activities, but only where      •                                                50% of such receipts if either the pickup or delivery associated with 
    such activity or activities are performed pursuant to a contract with                                                       those receipts is made in this City.  
    the investment company entered into according to the federal In-            
    vestment Company Act of 1940, section 15(a), as amended.                   In the EW row, enter the amount of receipts from all such activity. 
                                                                                
•   Distribution services means the services of advertising, servicing         Line 47 – Other aviation services                                           – For the New York City and EW 
    investor accounts (including redemptions), marketing shares or sell-       columns, determine the portion of receipts from aviation services, other 
    ing shares of an investment company; but in the case of advertising,       than services described in line 46 (but including the receipts of a quali-
    servicing investor accounts (including redemptions) or marketing           fied air freight forwarder, as described below) to enter by multiplying 
    shares, only where such service is performed by a person who is            those receipts by the average of lines 2, 4, and 6 in the worksheet below.    
    (or was, in the case of a closed end company) also engaged in the                                                                                                                                                             
                                    BUSINESS ALLOCATION FOR AVIATION CORPORATIONS
                                                                                                                                             AVERAGE FOR THE YEAR 
                                                                                                                                 COLUMN A - NEW YORK CITY                COLUMN B - EVERYWHERE 
1.  Aircraft arrivals and departures ...................................................................................1. 
2.  New York City percentage (column A divided by column B)........................................2.                                                                                                                           % 
3.  Revenue tons handled ................................................................................................3.                                                                                                     %
4.  New York City percentage (column A divided by column B)........................................4. 
5.  Originating revenue .....................................................................................................5. 
6.  New York City percentage (column A divided by column B)..................................................................................................................................6.                                 %  
7.  Total of lines 2, 4 and 6 .........................................................................................................................................................................................7.       % 
8.  Allocation percentage (line 7 divided by three rounded to the nearest one hundredth of a percentage point) .....................................................8.                                                          %
9.  Enter 100% of receipts from other aviation services; also enter on line 47b (EW row) of Form  
    NYC-2.5A or Column A (Everywhere column) of Form NYC-2.5A/BC , as applicable............................................................9. 
10. Multiply line 8 by line 9; also enter on line 47a (NYC row) of Form NYC-2.5A or column B 
    (New York City column) of  line 47 of Form NYC-2.5A/BC, as applicable  ...........................................................................10.

 Instructions for Form NYC-2.5A - 2022                                                                                                          Page 8
Aircraft arrivals and departures means the number of landings and takeoffs in     SECTION 11-654.2(10) – RECEIPTS FROM OTHER SERV-
the tax year, plus the number of air pickups and deliveries by such aircraft.  Do ICES/ACTIVITIES NOT SPECIFIED 
not include arrivals and departures solely for maintenance, repair, or refu-       
eling (where no debarkation or embarkation of traffic occurs). Arrivals and       Line 52 – In the New York City row, enter receipts from services and other 
departures of ferry and personnel training flights, or in the event of emer-      business receipts not reported on lines 1 through 53c, if the location of the cus-
gency situations, are also not included. Arrivals and departures of flights       tomer is within the City. The determination of the amount of receipts included 
transporting officers and employees receiving air transportation are included     in the New York City row is made according to the Hierarchy of methods 
(but see Note below for exceptions) without regard to remuneration.               below.  Each corporation must exercise due diligence under each method de-
                                                                                  scribed before rejecting it and proceeding to the next method in the hierarchy, 
Note: The Commissioner of Finance may exempt from the calculation ar-             and must base its determination on information known to the corporation, or 
rivals and departures of all non-revenue flights including flights involving      information that would be known to the corporation upon reasonable inquiry. 
the transportation of officers and employees receiving air transportation          
to perform maintenance or repair services, or where such officers or em-          Hierarchy of methods 
ployees are transported in conjunction with an emergency situation or the          
investigation of an air disaster (other than on a scheduled flight).              1)  The benefit is received in this City. 
                                                                                  2)  Delivery destination. 
Revenue tons handledmeans the weight, in tons, of revenue passengers              3)  The receipts fraction for such receipts within the City determined 
(at 200 pounds per passenger) and revenue cargo first received, either as             according to §11-654.2(10) for the preceding tax year. 
originating or connecting traffic or finally discharged at an airport. 
                                                                                  4)  The receipts fraction for the current tax year determined according 
Originating revenue means revenue to the taxpayer from the transporta-                to §11-654.2(10) for those receipts that can be sourced using the hi-
tion of revenue passengers and revenue property first received by the                 erarchy of sourcing method in item 1 or 2. 
taxpayer as originating or connecting traffic at airports.                        Note: Item 3 does not apply to your first tax period that begins on or 
 
                                                                                  after January 1, 2015, for which you are subject to Subchapter 3-A, or 
A corporation is a qualified air freight forwarder with respect to another 
                                                                                  your first tax year in New York City. 
corporation   if:                                                                  
•  it owns or controls, either directly or indirectly, all of the capital         SECTION 11-654.2(11) – DISCRETIONARY ADJUSTMENTS 
   stock of such other corporation; or if all of its capital stock is owned        
   or controlled, either directly or indirectly, by such other corpora-           Line 53 – Discretionary Adjustments.       If it appears that the receipts 
   tion; or if all of the capital stock of both corporations is owned or          allocation fraction determined according to §11-654.2 does not result in 
                                                                                  a proper reflection of the taxpayer’s business income or capital within 
   controlled, either directly or indirectly, by the same interests;              New York City, the Commissioner of Finance is authorized in his or her 
 • it is principally engaged in the business of air freight forwarding; and       discretion to adjust it, or the taxpayer may request that the commissioner 
•  its air freight forwarding business is carried on principally with the         adjust it. This is done by: 
   airline or airlines operated by such other corporation.                        •   Excluding one or more items in such determination, 
                                                                                  •   Including one or more items in such determination, or 
SECTION 11-654.2(8) – ADVERTISING: NEWSPAPERS/PERIODI-                            •   Any other similar or different method calculated to effect a fair and 
CALS, TV/RADIO, AND OTHER MEANS                                                       proper apportionment of the business income and capital reasonably 
 
Line 48 – For the New York City row, multiply receipts from sales of ad-              attributable to the City.  
                                                                                   
vertising in newspapers or periodicals by a fraction, the numerator of            The party seeking the adjustment bears the burden of proof to demonstrate 
which is the number of newspapers and periodicals delivered to points             that the receipts allocation fraction determined according to §11-654.2 
within the City, and the denominator of which is the number of newspa-            does not result in a proper reflection of the taxpayer’s business income or 
pers and periodicals delivered to points both within and outside the City.        capital within the City and that the proposed adjustment is appropriate. 
                                                                                   
Line 49 – For the New York City row, multiply receipts from sales of ad-          Where you have received approval from the commissioner to make such 
vertising on television or radio by a fraction, the numerator of which is the     adjustment, use line 53 to report it. Do not use line 53 to report an adjust-
number of viewers or listeners within the City, and the denominator of            ment unless you have received the approval of the commissioner. If you 
which is the number of viewers or listeners both within and outside the City.     have not received the approval of the commissioner before filing this re-
 
Line 50 – For the New York City row, multiply receipts from sales of ad-          turn, you must file using the statutory rules for allocation. You may file an 
vertising not reported on either line 48 or 49 that is furnished, provided, or    amended return after you have received approval.      
                                                                                   
delivered to or accessed by the viewer or listener through the use of wire, 
                                                                                  SECTION 11-654.2(5-A) – GLOBAL INTANGIBLE LOW-TAXED 
cable, fiber-optic, laser, microwave, radio wave, satellite or similar succes-
                                                                                  INCOME 
sor media, or any combination of these by a fraction, the numerator of which       
is the number of viewers or listeners within the City, and the denominator of     Line 53c – Enter in the Everywhere column the amount of Global Intan-
which is the number of viewers or listeners both within and outside the City.     gible Low-Taxed Income (GILTI) that constitutes business income for 
                                                                                  City tax purposes and was required to be included in federal gross in-
SECTION 11-654.2(9) – RECEIPTS FROM THE TRANSPORTATION                            come pursuant to IRC section 951A, less the corresponding IRC section 
OR TRANSMISSION OF GAS THROUGH PIPES                                              250(a)(1)(B)(i) amount as reduced by IRC section 250(a)(2) (if applicable). 
 
Line 51 – For the New York City row, multiply receipts from the trans-            Note that GILTI is considered business income if the underlying stock that 
portation or transmission of gas through pipes by a fraction, the numer-          generates the GILTI is business capital. GILTI amounts should not be in-
ator of which is the taxpayer’s transportation units within the City, and         cluded in the numerator of the combined group’s receipts factor. You must 
the denominator of which is the taxpayer’s transportation units both              attach to the combined return a statement detailing your computation of the 
within and outside the City.  A transportation unit is the transportation         amount of GILTI included in the Everywhere column, as well as Forms 
of one cubic foot of gas over a distance of one mile.                             8992 and 8993 or pro forma Forms 8992 and 8993, and Schedule I-1 of 
                                                                                  Form 5471. See Finance Memorandum 18-9.  

 Instructions for Form NYC-2.5A - 2022                                                                                                     Page 9

Worksheet A – Gross proceeds factors and net gains – Form NYC-              Amounts less than zero are allowed in an entity’s column A, rows a, b, d, and 
2.5A and Form NYC-2.5A/BC, lines 10, 12, 21, and 24 and Worksheet           e only. For rows a and b, the gross proceeds amounts are determined after 
D lines 10, 12, 21, and 24.                                                 the deduction of any cost incurred to acquire the securities. 
                                                                             
                                                                            Columns B, C, D, and E are completed on a combined basis, as in-
General information                                                         structed below. 
                                                                             
This worksheet computes the amounts for Forms NYC-2.5A and NYC-             Line instructions for Worksheet A 
2.5A/BC lines 10, 12, 21, and 24, as well as the amounts for these lines     
for Worksheet D, Designated agent’s NYC Receipts for purposes of fixed      Column A – Complete column A using the instructions for Condition 1 
dollar minimum (FDM) tax base. The line numbers correspond to the line      or Condition 2 below, whichever applies.   
                                                                             
numbers on Form NYC-2.5A. See the corresponding Form NYC-2.5A               Condition 1 – Use Condition 1 for: 
line instructions and also the specific instructions below.                 •  line 10 
 
In the instructions below, all lines refer to lines 10, 12, 21, and 24, and •  line 12 when the QFI box on line 12 (of Form NYC-2.5A) is                    not      
specific rows (a, b, c, d, e, or f) are indicated to clarify which rows of     marked;  
these lines the specific instruction applies to.                             • line 21 when the QFI box above line 19 (of Form NYC-2.5A) is not marked;  
                                                                            •  line 24 when the QFI box above line 22 (of Form NYC-2.5A) is                 not 
Worksheet A, column A (for all lines, rows a through f) is completed           marked;  
for the designated agent and for each combined member, in the manner 
set forth in these instructions.  Therefore, there should be as many        •  lines 12, 21, and 24 when the fixed percentage method for QFIs is not in 
columns A completed as there are entities in your combined return. Enter       effect for the combined group (Form NYC-2.5A, line 8 box is not marked).  
                                                                             
the EIN of the applicable entity at the top of each column A completed.     1.1. In each entity’s column A, for all lines, rows a and b respectively, enter that en-
                                                                               tity’s NYC and EW gross proceeds amount for that line’s category of receipts. 

 Instructions for Form NYC-2.5A - 2022                                                                                                           Page 10
     Example: Entity X is a member of a combined group and is completing            •   only use Condition 2 for line 24 when the QFI box above line 22 (of 
     a column A for itself. Entity X has receipts from the sales of loans se-           Form NYC-2.5A) is also marked; 
     cured by real property to report on Worksheet A, line 10. The amount of        •   never use Condition 2 for line 10. 
     all such sales of loans secured by real property for Entity X is $10 mil-       
     lion. The cost incurred to acquire such loans that were sold by Entity X       2.1. In each entity’s column A, leave rows a through c blank, for such 
     is $3 million. Entity X enters 7 million in Line 10, column A, row 10b              specific line(s). 
     (EW). Entity X must now determine the receipts from the sales by Entity        2.2. In each entity’s row d, for such specific lines, enter that entity’s EW 
     X of loans secured by real property located within New York City, and               net gains for the net gains being reported on each such line. 
     subtract from that amount the cost incurred to acquire such loans. The re-
     sult of this subtraction is entered in Line 10, column A, row 10a (NYC).       2.3. In each entity’s column A, rows e and f, for such specific line(s), mul-
                                                                                         tiply row d for each respective entity by 8% (.08) and enter the result; 
1.2. In each entity’s column A, for all lines, row c, divide the amount in               however, if the result is an amount less than zero, enter the negative 
     column A, row a by the amount in such column A, row b, and enter                    amount with a minus (-) sign in row e, but enter  0in row f. 
     the result rounded to four decimal places; however, if either the               
     amount in row a or the amount in row b for an entity is an amount              Columns B through E 
     less than  or equal to zero, enter  .0Row c is the NYC gross pro-              For any of lines 12, 21, and 24 for which Condition 2 applies, leave rows 
     ceeds factor for each entity, for each respective line, computed on            a and b of columns B through D blank. 
                                                                                     
     a separate company basis. It is used to compute the row f (NYC 
                                                                                    For column B, for all lines for which the immediately preceding para-
     FDM) amount for all lines in each entity’s column A.                           graph didnot apply, enter in row  a  the amount of the combined group’s 
1.3. In each entity’s column A, for each line, row d, enter that entity’s           NYC    gross proceeds generated from intercorporate transactions for the 
     EW net gains for the net gains being reported on each such line. If            receipts being reported on  that line; enter in row  bthe amount of the 
     the netting of gains and losses for a particular line, for a particular        combined group’s      EW gross proceeds generated from intercorporate 
     entity, results in zero, or less, enter in row d zero, or the negative         transactions for the receipts being reported on that line.  
                                                                                     
     amount, as the case may be.                                                    For column C, for all lines for which amounts are entered in column B, 
Note: To complete each line’s column E, which is needed for 1.4 below, you          enter in column C the sum of all entities’ column A, row a less any in-
must first complete, for all lines, that line’s row a, columns B and C and row      tercorporate eliminations in column  Bfor row a. For column  ,Dfor all 
b, columns B and D. Move to theColumns B through E instruction now.                 lines for which amounts are entered in column B, enter in column D the 
1.4. In each entity’s row e, for each line, multiply the factor in column           sum of all entities’ column A, row b less any intercorporate eliminations 
     E, of that line’s row c (the combined NYC gross proceeds factor) by            in column  Bfor row b.     However, if the resulting combined total forei-
     the amount in of that line’s row d for each respective entity, and             ther row is less than zero, enter  0for that row.  
                                                                                     
     enter the result. If the result is less than zero, enter the negative 
                                                                                    For column E, all lines, row c, divide column C by column D for each line 
     amount with a minus (-) sign.                                                  and enter the result rounded to four decimal places; however, if either 
1.5. In each entity’s row f, for each line, multiply the factor in that line’s col- column C or column D is less than  orequal to zero, enter  . This0 is the 
     umn A, row c (the NYC gross proceeds factor on a separate company              combined NYC gross proceeds factor for each respective line. It is used 
     basis) by the amount in that line’s row d for each respective entity, and      to compute the row e amount for all lines in each entity’s column A. 
     enter the result (but not less than zero). For FDM purposes only, the net       
     gains (not less than zero) are computed on a separate company basis.            Where are the amounts calculated on Worksheet A entered? 
 
Condition 2 – Use Condition 2 when the fixed percentage method for                  The amounts entered or calculated in columns B, C, D, and E are only 
QFIs  isin effect for the combined group (Form NYC-2.5A, line 8 box  is             used for Worksheet A calculations and do not get transferred to any other 
                                                                                    form or worksheet. The amounts entered or calculated in rows a, b, and 
marked). However:                                                                   c, for all lines, are also only used for Worksheet A calculations and do not 
•  only use Condition 2 for line 12 when the QFI box on line 12 (of Form            get transferred to any other form or worksheet. The amounts entered or 
   NYC-2.5A) is also marked;                                                        calculated in rows d, e, and f need to be entered on Form NYC-2.5A, 
•  only use Condition 2 for line 21 when the QFI box above line 19 (of              Form NYC-2.5A/BC, or Worksheet D, as follows:   
   Form NYC-2.5A) is also marked;                                                    

 Amount from Worksheet A, column A                                                    Amount is entered on 
 completed for the designated agent                                                    
 Line 10d (EW).......................................................................  NYC-2.5A, column A, line 10b (EW) 
 Line 10e (NYC) .....................................................................  NYC-2.5A, column A, line 10a (NYC) 
 Line 10f (NYC FDM)..............................................................      Worksheet D, line 10 (NYC FDM) 
 Line 12d (EW).......................................................................  NYC-2.5A,  column A, line 12b (EW) 
 Line 12e (NYC) .....................................................................  NYC-2.5A,  column A, line 12a (NYC) 
 Line 12f (NYC FDM)..............................................................      Worksheet D, line 12 (NYC FDM) 
 Line 21d (EW).......................................................................  NYC-2.5A,  column A, line 21b (EW) 
 Line 21e (NYC) .....................................................................  NYC-2.5A,  column A, line 21a (NYC) 
 Line 21f (NYC FDM)..............................................................      Worksheet D, line 21 (NYC FDM) 
 Line 24d (EW).......................................................................  NYC-2.5A,  column A, line 24b (EW) 
 Line 24e (NYC) .....................................................................  NYC-2.5A,  column A, line 24a (NYC) 
 Line 24f (NYC FDM)..............................................................      Worksheet D, line 24 (NYC FDM) 

 Instructions for Form NYC-2.5A - 2022                                                                                        Page 11

Amount from Worksheet A, column A                                                    Amount is entered in each entity’s Form  
completed for each combined entity                                                   NYC- 2.5A/BC, as follows: 
other than the designated agent                                                       
Line 10d (EW)....................................................................... NYC-2.5A/BC,  column A, line 10 (EW) 
Line 10e (NYC) ..................................................................... NYC-2.5A/BC,  column B, line 10 (NYC) 
Line 10f (NYC FDM) .............................................................     NYC-2.5A/BC,  column C, line 10 (NYC FDM) 
Line 12d (EW)....................................................................... NYC-2.5A/BC,  column A, line 12 (EW) 
Line 12e (NYC) ..................................................................... NYC-2.5A/BC,  column B, line 12 (NYC) 
Line 12f (NYC FDM) .............................................................     NYC-2.5A/BC,  column C, line 12 (NYC FDM) 
Line 21d (EW)....................................................................... NYC-2.5A/BC,  column A, line 21 (EW) 
Line 21e (NYC) ..................................................................... NYC-2.5A/BC,  column B, line 21 (NYC) 
Line 21f (NYC FDM) .............................................................     NYC-2.5A/BC,  column C, line 21 (NYC FDM) 
Line 24d (EW)....................................................................... NYC-2.5A/BC,  column A, line 24 (EW) 
Line 24e (NYC) ..................................................................... NYC-2.5A/BC,  column B, line 24 (NYC) 
Line 24f (NYC FDM) .............................................................     NYC-2.5A/BC,  column C, line 24 (NYC FDM) 

 Instructions for Form NYC-2.5A - 2022                        Page 12

Worksheet B – Net gains and other income – Form NYC-2.5A and 
Form NYC-2.5A/BC, line 30 and Worksheet D, line 30            

 Instructions for Form NYC-2.5A - 2022                                                                                                   Page 13

                                                                              1.2. For such  lines 30.1 and 30.2,row c , enter the amount entered in 
General information                                                                row b for that entity, for that line, except that if the row b amount 
                                                                                   for that entity is less than zero, enter 0. For fixed dollar minimum 
This worksheet computes certain amounts for Forms NYC-2.5A and                     purposes only, the net gains (not less than zero) and “other” income 
NYC-2.5A/BC, line 30, as well as the amount for Worksheet D, line 30.              (not less than zero) are computed on a separate company basis. Use 
Line number 30 corresponds to the same line number on Form NYC-                    a separate line 30.1 for net gains from sales of “other” financial in-
2.5A. See the corresponding line instructions for Form NYC-2.5A and                struments of each certain type, and a separate line 30.2 for “other” 
also the specific instructions below. In the instructions below, all lines         income from all “other” financial instruments of each certain type. 
refer to lines 30.1, 30.2, 30.3, 30.4, 30.5, and 30, and specific rows (a,     
b, or c) are indicated to clarify which rows of these lines the specific      Condition 2 –If the fixed percentage method for QFIs  isin effect for the 
instruction applies to. Note: Lines 30.1 through 30.5 are specific to         combined group (Form NYC-2.5A, line 8 box  ismarked YES)       and: 
this worksheet only. Since Form NYC-2.5A, line 30 is comprised of              
different types of receipts that have to be netted separately, these re-      2.1. the clause (viii) QFI box is not marked on Form NYC-2.5A, above 
ceipts amounts are shown separately on lines 30.1 through 30.5.                    line 29, each entity’s column A, lines 30.1 and 30.2, rows b and c, 
                                                                                   are completed in the same manner as if the fixed percentage method 
Column A (for all lines, rows a through c), is completed for the designated        is not in effect  (see above instructions). 
agent and for each combined member, in the manner set forth in these in-       
structions. There should be as many columns A completed as there are enti-    2.2  the clause (viii) QFI box  ismarked on Form NYC-2.5A, above line 
ties in your combined return that have line 30 receipts. Enter the EIN of the      29, and the receipts to be reported on a line 30.1 or 30.2 represent 
applicable entity at the top of each column A completed.                           receipts from QFIs (see instructions for NYC-2.5A, line 8) , in each 
 
                                                                                   entity’s column A, for such lines 30.1 and 30.2, rows b and c, mul-
Amounts less than zero are allowed in an entity’s column A, rows a and b. 
                                                                                   tiply column A, row a, for each respective entity and line, by 8% 
Columns B, C, and D are completed only once on a combined group basis. 
                                                                                   (.08) and enter the result; however, if the result is an amount less 
Line instructions for Worksheet B Part 1                                           than zero, enter the negative amount with a minus (-) sign in row 
Only clause (viii) receipts are reported in Par 1.                                 b, but enter  0in row c. Use a separate line 30.1 for net gains from 
                                                                                   sales of all “other” financial instruments of each certain type, and 
Step 1 – Column A, lines 30.1 and 30.2, row a – Regardless of whether              use a separate line 30.2 for “other” income from all “other” finan-
or not the fixed percentage method is in effect for the combined group, for        cial instruments of each certain type. 
lines 30.1 and 30.2 for   row a (EW)in each entity’scolumn A follow the        
applicable instructions for Form NYC-2.5A, line 30 to determine the           Step 3 – Column B – Foreach line 30.1 and 30.2, enter in column B, in 
amount of everywhere receipts, except that if the amount is less than zero,   row a (EW) and in row b (NYC) of each such lines, the amount of the 
enter the negative amount with a minus (-) sign.                              combined group’s receipts generated from intercorporate transactions that 
                                                                              are included on each such lines, row a and row b, of column A. 
When you have net gains from sales of more than one type of “other”            
financial instruments, use separate lines 30.1 to report sales of all         Step 4 – Columns C and D – For all lines 30.1 and 30.2, rows a and b, 
“other” financial instruments of each such type. The same is true for         enter the result of taking the sum of the amounts for each such line and 
lines 30.2 when reporting “other” income from “other” financial in-           row entered in each entity’s column A (i.e., the   sum of all entities’ 
struments.                                                                    columns A, rows a and b, respectively) less any intercorporate elimina-
                                                                              tions in column B for each such line and  row; however, if the resulting 
If you have receipts reportable on lines 30.1 or 30.2 from more than          combined total for either row is less than zero, enter 0 for that row. 
three separate types of “other” financial instruments, use an additional       
line 30.1 or line 30.2 for each additional separate type of “other” fi-       Part 2 
nancial instrument for which you have gains/(losses) (line 30.1) or           Only clause (vii) receipts are reported in Part 2. 
“other” income/(loss) (line 30.2); include the amounts from these addi-        
tional lines in the same manner as you would for the lines 30.1 and 30.2      Part 2 of Worksheet B must only be completed if the fixed percentage 
provided on the worksheet, as you complete the steps below, as appli-         method for QFIs  isin effect. If Form NYC-2.5A, line 8 box isnot marked 
cable.                                                                        YES, leave lines 30.3, 30.4, and 30.5 blank and continue with Totals of 
                                                                              Parts 1 and 2 instructions below; otherwise continue with Step 1 below. 
Step 2 – Complete column A, lines 30.1 and 30.2, rows b and c, using the       
instructions for Condition 1 or Condition 2 (or both), as applicable.         Step 1 – Columns A, B, C and D, lines 30.3 and 30.4, rows a, b, and c 
                                                                              – If the fixed percentage method for QFIs  isin effect and any member of 
Condition 1 – If the fixed percentage method for QFIs is not in effect for    the combined group in the tax year has marked to market any stock under 
the combined group (Form NYC-2.5A, line 8 box is not marked YES);             IRC section 475 or 1256, complete substeps 1.1, 1.2, and 1.3 below; oth-
or if the receipts from lines 30.1 and 30.2 do not represent receipts from    erwise leave lines 30.3 and 30.4 blank and continue with Step 2 below. 
QFIs(see instructions for Form NYC-2.5A, line 8):                              
                                                                              1.1. In each entity’s column A, enter on line 30.3, row a, 100% of div-
1.1.  For such lines 30.1 and 30.2, row b, follow the applicable line 30           idends from stock that is business capital, provided that dividends 
      instructions to determine the amount of NYC receipts, except that            that qualify as other exempt income should not be included. In each 
      if the amount is less than zero, enter the negative amount with a            entity’s  column A, enter on   line 30.4, row a, 100% of net gains 
      minus (-) sign.  Use a separate line 30.1 for net gains from sales of        from sales of stock that is business capital; if the amount is less 
      all “other” financial instruments of each certain type, and use a sep-       than zero, enter the negative amount with a minus (-) sign.  
      arate line 30.2 for “other” income from all “other” financial in-        
      struments of each certain type.                                               1.1.1. In each entity’s column A, lines 30.3 and 30.4, rows b and 
                                                                                          c, multiply column A, row a, for each respective entity and 

 Instructions for Form NYC-2.5A - 2022                                                                                                 Page 14

             line, by 8% (.08) and enter the result; however, if the result              in row b, but enter  0in row c.  
             is an amount less than zero, enter the negative amount with       
             a minus (-) sign in row b, but enter  0in row  . c               2.2. Incolumn B, forline 30.5, rows a and b, enter the amount of EW 
                                                                                   and NYC receipts generated from intercorporate transactions, re-
1.2.  In column B, for   lines 30.3 and 30.4, rows a and b, enter the              spectively, from that category of receipts. 
      amount of EW and NYC receipts generated from intercorporate              
      transactions, respectively, from that category of receipts.             2.3. Incolumns C and D,for line 30.5, rows a and b, enter the result 
                                                                                   of taking the sum of the amounts for each such row entered in each 
1.3.  In columns C and D, for lines 30.3 and 30.4, rows a and b, enter             entity’s column A (i.e., the sum of all entities’ columns A, rows a 
      the result of taking the sum of the amounts for each such row en-            and b, respectively) less any intercorporate eliminations in column 
      tered in each entity’s column A (i.e., the     sum of all entities’          B for each such row; however, if the resulting combined total for 
      columns A, rows a and b, respectively)less any intercorporate elim-          either row is less than zero, enter  0for that row. 
      inations in column B for each such row; however, if the resulting        
      combined total foreither row is less than zero, enter  0  for that row. Totals of Parts 1 and 2 
                                                                               
Step 2 –Columns A, B, C and D, line 30.5, rows a, b, and c        – If the    Step 1 –Column A, line 30, row c    – Enter online 30, row c thesum of 
fixed percentage method for QFIs  isin effect, and any member of the          the amounts in column A, row c, lines 30.1 through 30.5 forthat entity. 
combined group in the tax year has marked to market any partnership in-        
terest in a widely held or publicly traded partnership under IRC section      Step 2 – Column D, line 30, and column C, line 30. 
                                                                               
475 or 1256, complete substeps 2.1, 2.2, and 2.3 below; otherwise leave       2.1. For column D, line 30 enter the sum of the amounts in column D, 
line 30.5 blank and continue with Totals of Parts 1 and 2 below.                   lines 30.1 through 30.5. 
                                                                               
2.1.  In each entity’s column A, enter on line 30.5, row a, 100% of net       2.2. For column C, line 30, enter the sum of the amounts in column C, 
      gains from sales of partnership interests in widely held or publicly         lines 30.1 through 30.5. 
      traded partnerships; if the amount is less than zero, enter the neg-     
      ative amount with a minus (-) sign.                                     Where are the amounts calculated on Worksheet B entered? 
                                                                              The amounts entered or calculated on lines 30.1 through 30.5 are used to 
      2.1.1. In each entity’s column A, line 30.5, rows b and c, multiply     compute the line 30 totals and do not get transferred to any other form or 
             column A, row a, for each respective entity and line, by 8%      worksheet; the line 30 totals need to be entered on Form NYC-2.5A, Form 
             (.08) and enter the result; however, if the result is an amount  NYC-2.5A/BC, or Worksheet D, as follows: 
             less than zero, enter the negative amount with a minus (-) sign   

 AMOUNT FROM WORKSHEET B                                                       AMOUNT IS ENTERED ON 
  
 Column A          completed for 
 the designated agent                    
 Line 30c (Total NYC FDM)                                                      Worksheet D, line 30 (NYC FDM) 
  
 Column A          completed for 
 each combined entity other 
 than the designated agent                                                     each entity’s Form NYC-2.5A/BC, 
 Line 30c (Total NYC FDM)                                                      column C, line 30 (NYC FDM) 
  
 Column C                                                                      Form NYC-2.5A, column D,  
 Line 30b (Total NYC)                                                          line 30a (NYC) 
  
 Column D                                                                      Form NYC-2.5A,  column E, 
 Line 30a (Total EW)                                                           line 30b (EW)

 Instructions for Form NYC-2.5A - 2022 Page 15

(Continued)

 Instructions for Form NYC-2.5A - 2022                                                                                               Page 16

Worksheet C – Marked to market (MTM) net gains – Form NYC-                  Part 2 of the worksheet is generally only applicable if the 8% fixed per-
2.5A and Form NYC-2.5A/BC, line 28 and Worksheet D, line 28                 centage method for QFIs is   not in effect. Provided however, that if the 
                                                                            8% fixed percentage method for QFIs   isin effect,  and you have MTM 
                                                                            gains/(losses) reportable on line 10  of the worksheet, you may have to 
General information                                                         complete Part 2 of the worksheet, as instructed further below.  Part 2 
                                                                            computes the NYC aggregate MTM factor for each entity in the com-
Note: You must first complete Worksheets A and B, and lines 9 through       bined return, and also computes the combined NYC aggregate MTM 
27, 29, and 30 of  Worksheet D and Forms NYC-2.5A and NYC-                  factor for the combined group. These factors are used to determine NYC 
2.5A/BC, then, follow the steps below, in order, to complete Worksheet      MTM net gains under (x)(C) in Part 1, as per the specific line instructions 
C.                                                                          for columns A and B, under Customer-based sourcing below. 
                                                                             
This worksheet computes the amounts for Forms NYC-2.5A and NYC-             Column A (for all lines in all parts of the worksheet) is completed for the 
2.5A/BC, line 28, and the amount for line 28 of Worksheet D, Desig-         designated agent and for each combined member, in the manner set forth 
nated agent’s NYC Receipts for purposes of fixed dollar minimum (FDM)       in these instructions.  Column A, row B amounts are used to determine 
tax base.  See the corresponding  instructions for NYC-2.5A and also        an entity’s row c amounts.  There should be as many columns A com-
the specific instructions below. For purposes of Worksheet C, §11-          pleted as there are entities in your combined return. Enter the EIN of the 
654.2(5)(a)(2)(x)(B) is referred to as (x)(B) and §11-654.2(5)(a)(2)(x)(C)  applicable entity at the top of each column A completed. 
as (x)(C).  (x)(B) sources MTM net gains based on the sourcing of net        
gains from actual sales of financial instruments of the same type. (x)(C)   Amounts less than zero are allowed in an entity’s Part 1, column A, row a. 
is used when there are no actual sales of a type, or the actual sales of a   
type resulted in a net loss of that type.                                   Line instructions for Worksheet C 
                                                                             If the 8% fixed percentage method for QFIs   iniseffect (Form NYC-
Part 1 of the worksheet computes MTM net gains for those financial in-      2.5A, line 8 box  ismarked), you  must complete the steps under the8% 
struments that are described on Form NYC-2.5A, lines 10, 12, 16, 18,        fixed percentage method elected instructions below to complete Work-
20, 21, 23, 24, 27, and 30, and that have been MTM. Columns A and           sheet C. Do not complete the steps under the Customer-based sourcing 
B, row b are broken out into subcolumns for lines 10, 12, 16, 18, 20, 21,   instructions, unless specifically instructed to do so for a certain line. 
23, 24, 27 and all lines 30. For each such line in columns A and B, re-      
spectively, only one of the subcolumns will apply for that line, depend-    If the fixed percentage method for QFIs is not in effect (Form  NYC-2.5A line 
ing on the sourcing rule that applies for that line; the subcolumns that do 8 box is not marked YES), you must complete the steps under the Customer-
not apply in columns A and B should be left blank.                          based sourcing instructions below to complete Worksheet C. Do not complete 
                                                                            the steps under the 8% fixed percentage method elected instructions. 

 Instructions for Form NYC-2.5A - 2022                                                                                                     Page 17

Regardless of whether or not the 8% fixed percentage method for QFIs               method sourcing is in effect for QFIs. 
is in effect, use a separate line 30 for MTM gains/(losses) from all “other”   
financial instruments of one same certain type. If you need more than         1.3. In row c, (NYC FDM), lines 12, 16, 18, 20, 21, 23, 24, 27, all lines 30, 
three lines 30, use an additional line 30 for each separate type of “other”        30-Stk, and 30-Pship, in each entity’s column A, enter the amount you 
financial instrument for which you have MTM gains/(losses); include the            entered in row b, subcolumn 8% for that line. 
amounts from these additional lines in the same manner as you would for        
the line 30 provided on the worksheet as you complete the steps below,        1.4. In row c, for line 28, in each entity’s column A, enter the sum of the 
as applicable.                                                                     amounts from row  cin lines 10, 12, 16, 18, 20, 21, 23, 24, 27, all 
                                                                                   lines 30, 30-Stk, and 30-Pship, for that entity. 
8% fixed percentage method elected.                                            
                                                                              Step 2 – Part 1, column C, row a  
When the 8% fixed percentage method for QFIs is in effect follow the in-       
structions for Condition 1 or Condition 2 below, whichever applies.           2.1. In column C, lines 10, 12, 16, 18, 20, 21, 23, 24, 27, all lines 30, 30-
When Condition 1 applies, only Part 1 of Worksheet C needs to be com-              Stk, and 30-Pship, enter the sum of all entities’ column A, row a, 
pleted, and the Part 1, (x)(B) Totals section should be left blank. When           amounts for each such line.  However, if the resulting       combined 
Condition 2 applies, you may need to complete Part 2 of the worksheet,             total is less than or equal to zero for any such line, enter  0for col-
and the Part 1, (x)(B) Totals section.                                             umn C. 
                                                                               
Condition 1 – If you do not have MTM gains/(losses) reportable on line        2.2. In column C for line 28, enter the   sum of the amounts from col-
10 of this worksheet, completesteps 1 through  3below (under these 8%              umn C, row a for lines 10, 12, 16, 18, 20, 21, 23, 24, 27, all lines 30, 
fixed percentage method elected instructions) and do not complete any              30-Stk, and 30-Pship. 
of the steps under the Customer-based sourcing instructions.                   
                                                                              Step 3 – Part 1, column B, row b 
Condition 2 – If you have MTM gains/(losses) reportable on line 10 of          
this worksheet, you must determine the amounts to enter on line 10 by         3.1. In column B, lines 12, 16, 18, 20, 21, 23, 24, 27, all lines 30, 30-Stk, 
completing the applicable steps under Customer-based sourcing for line             and 30-Pship, row b, subcolumn 8%, of each such line, enter the 
10 only. When Condition 2 applies:                                                 product of: the amount in column C for that line, and 8% (.08). 
                                                                               
•  First, for line 10 only, complete steps 1.1 through 4.2 AND steps          3.2. In column B for line 28, Enter the sum of all amounts from all ap-
   5 through 9.1.2 under Customer-based sourcing (do not complete                  plicable subcolumns in column B, row  b    for lines 10,12, 16, 18, 20, 
   step 4.3 or step 10).                                                           21, 23, 24, 27, all lines 30, 30-Stk, and 30-Pship. 
                                                                               
•  Next, complete     all of steps 1 through 3 below (under these       8%    Customer-based sourcing 
   fixed percentage method elected instructions) for all remaining lines      Parts 1 and 2 of Worksheet C need to be completed when the 8% fixed 
   (including lines 30-STK and 30-Pship (if applicable)).                     percentage method for QFIs is not in effect. To complete Worksheet C 
                                                                              in this instance, follow Steps 1 through 10 below, in that order. 
Step 1 – Part 1, column A, rows a, b, and c                                    
                                                                              Note: Lines 30-Stk and 30-Pship should not be completed as these lines 
1.1. In row a (EW), lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines   are not applicable when customer-based sourcing is used (§11-
   30 (including lines 30-Stk and 30-Pship), in each entity’s column          654.2(5)(a)(2)(vii)).  
   A, enter 100% of each entity’s MTM net gains/(losses) for those fi-         
   nancial instrumentsdescribed on each such line (and described fur-         If the fixed percentage method for QFIs  isin effect  and you have MTM 
   ther in the corresponding line instructions for Form NYC-2.5A),            gains/(losses) reportable on line  10of this worksheet, then you must use 
   except that if the net amount is less than zero, enter the negative        customer-based sourcing for the MTM net gains for line 10 only. In this 
   amount with a minus (-) sign. If the amount is zero for an entity, for     instance, follow the instructions for Condition 2 under the 8% fixed per-
   any line, enter  0in row  afor that line.                                  centage method electedinstructions, above 
 
Note: Use line 30 for MTM net gains/(losses) from “other” financial in-        
struments (§11-654.2(5)(a)(2)(viii)). If any member of the combined           Step 1 – Part 1, column A, row a, and row b, subcolumn (x)(B)  
group in the tax year has marked to market any stock under IRC section         
475 or 1256, use line 30-Stk for MTM net gains/(losses) from sales of         1.1. In row a, lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines 30, in 
stock that is business capital (§11-654.2(5)(a)(2)(vii)); otherwise leave          each entity’s column A, enter      100% of each entity’s     MTM net 
line 30-Stk blank. If any member of the combined group in the tax year             gains/(losses) for those financial instruments described on each such 
has MTM    any partnership interest in a widely held or publicly traded            line (and described further in the corresponding line instructions for 
partnership under IRC section 475 or 1256, use line 30-Pship for MTM               Form NYC-2.5A), except that if the net amount is less than zero, 
net gains/(losses) from sales of partnership interests in widely held or           enter the negative amount with a minus (-) sign. If the amount is 
publicly traded partnerships (§11-654.2(5)(a)(2)(vii)); otherwise, leave           equal to zero for an entity, for any line, enter  0 in row a forthat line. 
line 30-Pship blank.                                                           
                                                                              1.2. Row b, subcolumn (x)(B)        - Subcolumn (x)(B), lines 10, 12, 16, 
1.2. In row b (NYC), subcolumn 8%, lines 12, 16, 18, 20, 21, 23, 24, 27,           18, 20, 21, 23, 24, 27, and all lines 30, in each entity’s column A, 
   all lines 30, 30-Stk, and 30-Pship, in each entity’s column A, multiply         is used to compute    NYC MTM net gains, for those financial in-
   column A, row  a,for each respective entity and line, by 8% (.08) and           strumentsdescribed on each such line, under the sourcing rules of 
   enter the result; if the result is less than zero, enter 0. You must leave      clause (x)(B) of §11-654.2(5)(a)(2).  Follow the steps below to 
   row b, subcolumn (x)(B) and row b, subcolumn (x)(C) blank for all               compute the subcolumn (x)(B) amounts. These amounts are com-
   such lines as they are not applicable when the 8% fixed percentage              puted on a separate company basis in column A, and are used in the 
                                                                                   computation of the NYC aggregate MTM factor in Part 2, column 

 Instructions for Form NYC-2.5A - 2022                                                                                                       Page 18
 A, and also used to compute NYC receipts for FDM purposes in                                  any specific line 30 is the amount from Worksheet B, 
 Part 1, row c. Complete substeps 1.2.1 through 1.2.4 for each line                            from that entity’s column A, line 30.1 (used to report the 
 (10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines 30) for each entity’s                      same specific type of financial instruments), row a (EW) 
 column A:                                                                                     (but not less than zero). However, if the numerator so de-
                                                                                               termined is zero, enter 0. 
 1.2.1. If the step 1.1 amount is less than  orequal to zero for an en-        
        tity, for any line, enter   in0 row  , subcolumnsb (x)(B) and              1.2.4. In each entity’s column A, for each line for which row a isnot 
        (x)(C), and row  cfor that entity, for   that line.                               less than or equal to zero, if that entity did  not have actual 
                                                                                          everywhere sales that generated a net  gain for the same spe-
 1.2.2. For each entity, for each line for which row a is not less than or                cific type of financial instrument described in such line (as de-
        equal to zero, determine if that entity has     actual everywhere                 termined in substep 1.2.2 above), leave row b, subcolumn 
        sales that generated a net gain during the tax year, for that type                (x)(B) blank for that line. 
        of financial instrument. An entity,    other than the designated            
        agent, had actual everywhere sales that generated a net gain          Step 2 – Part 1, column A, (x)(B) Total EW, and (x)(B) Total NYC 
        during the tax year for a specific type of financial instrument if     
        there is an amount greater than zero reported on that type of fi-     When you have completed each entity’s column A, Part 1, row a, and 
        nancial instrument’s corresponding line of Form NYC-                  row b subcolumn (x)(B), for lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and 
        2.5A/BC, Column A. The designated agent had actual sales that         all lines 30, you must next complete, for each entity’s column A, the 
        generated a net gain during the tax year for a specific type of fi-   (x)(B) Total lines for EW and NYC, which are directly below line 30-
        nancial instrument if there is an amount greater than zero re-        Pship. The clause (x)(B) totals are needed to calculate the New York City 
        ported on that type of financial instrument’s corresponding line      aggregate MTM factor in Part 2, Column A of this worksheet, when ap-
        of Form NYC-2.5A, column A, row b (EW). However, for line             plicable. 
        30, for all entities, an entity had actual everywhere sales that       
        generated a net gain during the tax year for the type of financial    2.1. In each entity’s column A, enter in the (x)(B) Total EW line, the 
        instrument described in §11-654.2(5)(a)(2)(viii) if there is an            sum of the column A,      row a amounts for all lines that have an 
        amount greater than zero reported on Worksheet B, in that en-              amount entered in column A, row b, subcolumn (x)(B), even if the 
        tity’s column A, line 30.1 (used to report the same specific type          amount entered is zero, but do not include in the sum any column 
        of financial instruments) row a.                                           A, row  aamounts that are    less than zero for a particular line. 
                                                                               
 1.2.3. In each entity’s column A, for each line for which row  a       isnot 2.2. In each entity’s column A, enter in the (x)(B) Total New York City 
        less than or equal to zero, if that entity did have actual every-          line, the sum of the row b, subcolumn (x)(B) amounts for all lines 
        where sales that generated a net gain for the specific type of fi-         that have an amount entered in column A, row b, subcolumn (x)(B). 
        nancial instrument described on such line (as determined in            
        substep 1.2.2 above), enter in that entity’s row b, subcolumn         Step 3 – Part 2, column A 
        (x)(B), for that line, the product of: the amount in that entity’s     
        row  afor such line, and a fraction, the numerator and the de-        Part 2 of the worksheet, column A, computes each entity’s NYC aggre-
        nominator of which are determined as follows:                         gate MTM factor, on a separate company basis, which you will need in 
                                                                              order to complete Part 1, row b, subcolumn (x)(C), when applicable. 
  •           If the entity is the designated agent, for all such lines (ex-   
              cept line 30): the numerator of the fraction for such line      Never include any amounts sourced under the 8% fixed percentage 
              (except line 30) is the amount from Form NYC-2.5A, col-         method election when determining the amounts to include in the sums 
              umn A, row a (NYC) of the corresponding line, and the           described in these step 3 instructions. 
              denominator of the fraction for such line (except line 30)       
              is the amount from Form NYC-2.5A,  column A, row b              3.1. Line A (NYC) – In each entity’s column A, enter on this line the re-
              (EW) of the corresponding line.  However, if the numer-              sult of the applicable instruction for that entity: 
              ator so determined is less than or equal to zero, enter  .0      
              For line 30, see the specific line 30 instructions below.            •      For the designated agent, enter the sum of: the (x)(B) Total NYC 
                                                                                          amount from the designated agent’s Part 1, column A of this 
  •           If the entity is an entity other than the designated agent,                 worksheet plus the amounts from Worksheet D, lines 9 through 
              for all such lines (except line 30): the numerator of the                   27, 29, and 30; (complete Worksheet D, except for Worksheet D, 
              fraction for such line (except line 30) is the amount from                  line 28, now if you have not done so already). 
              that entity’s Form NYC-2.5A/BC, column B (NYC) of                     
              the corresponding line, and the denominator of the frac-             •      For each entity other than the designated agent, enter the sum 
              tion for such line (except line 30) is the amount from that                 of: the (x)(B) Total NYC amount from that entity’s Part 1, col-
              entity’s Form NYC-2.5-A/BC, column A (EW) of the cor-                       umn A of this worksheet plus the amounts from that entity’s Form 
              responding line. However, if the numerator so determined                    NYC-2.5A/BC, column C, (NYC FDM) lines 9 through 27, 29, 
              is less than  orequal to zero, enter  . For0 line 30, see the               30, (for each member of the group, except the designated agent, 
              specific line 30 instructions below.                                        complete column C of Form NYC-2.5-A/BC,  now if you have 
                                                                                          not done so already). 
  •           Line 30 – For all entities, the numerator of the fraction        
              for any specific line 30 is the amount from Worksheet B,        3.2. Line B (EW) – In each entity’s column A, enter on this line the re-
              from that entity’s column A, line 30.1 (used to report the           sult of the applicable instruction for that entity: 
              same type of financial instruments), row b (NYC) (but            
              not less than zero). The denominator of the fraction for             •      For the designated agent, enter the sum of: the (x)(B) Total EW 

 Instructions for Form NYC-2.5A - 2022                                                                                                      Page 19

            amount from the designated agent’s column A, Part 1 of this        Step 5 – Part 1, column C, row a 
            worksheet plus the amounts (but not less than zero from any line)   
            from Form NYC-2.5A, column A, lines 9 through 27 and 29, row       In column C, lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines 30, 
            b (EW) plus the amounts (but not less than zero for any line) from enter the sum of all the amounts entered in each entity’s column A, row 
            the designated agent’s Worksheet B, column A, lines 30.1 and       a (EW), for each such line. However, if the resulting combined total is 
            30.2, row a (EW).                                                  less than or equal to zero for any such line, enter  0for column C. 
                                                                                
     •      For each entity other than the designated agent, enter the sum     Step 6 – Part 1, column B, row b, subcolumn (x)(B) 
            of: the (x)(B) Total EW amount from that entity’s Part 1, column    
            A, of this worksheet plus the amounts (but not less than zero from 6.1. Column B, subcolumn (x)(B) - Subcolumn (x)(B), lines 10, 12, 
            any line) from Form NYC-2.5A/BC, column A (EW) lines 9                  16, 18, 20, 21, 23, 24, 27, and all lines 30, in column B, is used to 
            through 27 and 29 plus any amounts (but not less than zero for any      compute NYC MTM net gains on a combined basis, for those fi-
            line) from that entity’s Worksheet B, column A, lines 30.1 and          nancial instruments described on each such line, under the sourc-
            30.2, row a (EW).                                                       ing rules of clause (x)(B) of §11-654.2(5)(a)(2). Follow the steps 
                                                                                    below to compute the Column B, subcolumn (x)(B) amounts. These 
3.3. Line C – For each entity’s column A, divide the line A amount by the           amounts are computed on a combined basis in column B, and are 
     line B amount and enter the result, rounded to four decimal places.            used in the computation of the combined NYC aggregate MTM 
                                                                                    factor in Part 2.  Complete the following steps for each line (10, 
Step 4 – Part 1, column A, row b, subcolumn (x)(C), and row c:                      12, 16, 18, 20, 21, 23, 24, 27, and all lines 30) for column B: 
                                                                                
4.1. Row b, subcolumn (x)(C) - Subcolumn (x)(C), lines 10, 12, 16,                  6.1.1. If the column C amount entered is equal to zero for an entity, 
     18, 20, 21, 23, 24, 27, and all lines 30, in each entity’s column A,                  for any line, enter  0in row b, subcolumns (x)(B) and (x)(C), 
     is used to compute    NYC MTM      net gains, for those financial in-                 and row  c for that entity, for that line. 
     struments described on each such line, under the sourcing rules of              
     clause (x)(C) of §11-654.2(5)(a)(2).  Follow the steps below to                6.1.2. For each line for which column C is not equal to zero, determine 
     compute the subcolumn (x)(C) amounts. These amounts are com-                          if the combined group has actual everywhere sales that gener-
     puted on a   separate company basis in column A. Complete sub-                        ated a net gain during the tax year, for that type of financial in-
     steps 4.1.1 and 4.1.2 for each line (10, 12, 16, 18, 20, 21, 23, 24, 27,              strument. The combined group had actual everywhere sales that 
     and all lines 30) for each entity’s column A:                                         generated a net gain during the tax year for a specific financial in-
                                                                                           strument if there is an amount greater than zero reported on the 
     4.1.1. For each entity, for each line, if there is an amount greater than             corresponding line of Form NYC-2.5A, column E, row b (EW).  
            or equal to zero entered in row b, subcolumn (x)(B), then                      However, for all lines 30, the  combined group had    actual 
            leave row b, subcolumn  (x)(C)   blank for that line, for that                 everywhere sales that generated a net gain for that type of fi-
            entity. Note: When an entity had actual everywhere sales that                  nancial instrument if there is an amount greater than zero re-
            generated a net gain for that type of financial instrument dur-                ported on the Worksheet B, column D, line 30.1 used to report 
            ing the tax year, subcolumn (x)(B) should have an amount en-                   the same specific type of financial instrument.  
            tered, and subcolumn (x)(C) should be left blank.                        
                                                                                    6.1.3. For each line for which column C is not equal to zero, if the 
     4.1.2. In each entity’s column A, for each line, if that entity did not               combined group did have actual everywhere sales that gen-
            have actual everywhere sales that generated a net gain for the                 erated a net gain for the same specific type of financial in-
            specific type of financial instrument described on that line                   strument described on that line (as determined in substep 
            (row b, subcolumn (x)(B) was left blank for that line per sub-                 6.1.2), enter in column B, subcolumn (x)(B), for that line, the 
            step 1.2.4), enter in that entity’s row b, subcolumn (x)(C), for               product of: the amount in column C for that line and a frac-
            that line, the product of: the amount in that entity’s row a                   tion, the numerator and the denominator of which are deter-
            (EW) for that line, and the factor in Part 2, line C of that en-               mined as follows: 
            tity’s column A.                                                    
                                                                                           •   the numerator of the fraction for such line (except line 
4.2. In row c, lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines 30, for                 30) is the amount from Form NYC-2.5A, column D of 
     each entity, for all lines that have an amount entered in row b, sub-                     the corresponding line, and the denominator of the frac-
     column (x)(B), enter the amount you entered in row b, subcolumn                           tion for such line (except line 30) is the amount from 
     (x)(B) for that line.  If row b, subcolumn (x)(B) is blank for any line                   Form NYC-2.5A,  column E of the corresponding line; 
     for an entity, enter the amount you entered in row b, subcolumn                           however, if the numerator so determined is less than or 
     (x)(C) for that line, for that entity.                                                    equal to zero, enter 0. 
                                                                                            
Note: for each entity’s column A, you must complete row b, subcolumn                       •   Line 30 – The numerator of the fraction for any specific 
(x)(C), for all lines that do not have an amount entered in row b, sub-                        line 30 is the amount from the Worksheet B, column C, 
column (x)(B), before you can complete row c for such lines (see row                           line 30.1 that is used to report the same specific type of 
b, subcolumn (x)(C) instructions above).                                                       financial instrument. The   denominator of the fraction 
                                                                                               for any specific line 30 is the amount from the Worksheet 
4.3. In row c, for line 28, in each entity’s column A, enter the sum of the                    B, column D, line 30.1 that is used to report the   same 
     amounts from row c in lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and                       specific type of financial instrument. However if the nu-
     30 for that entity.                                                                       merator so determined is zero, enter 0. 
                                                                                
                                                                                    6.1.4. For each line for which column C is  not equal to zero, if the 

 Instructions for Form NYC-2.5A - 2022                                                                                              Page 20

        combined group did     not have actual everywhere sales that            zero entered in column B, row b, subcolumn (x)(B), then leave 
        generated a net gain for the same specific type of financial in-        column B, row b, subcolumn (x)(C) blank for that line.  
        strument described in that line (as determined in substep          
        6.1.2), leave column B, row b, subcolumn (x)(B) blank for         Note: When the combined group had actual everywhere sales that gen-
        that line.                                                              erated a net gain on a combined basis for that type of financial 
                                                                                instrument during the tax year, subcolumn (x)(B) should have an 
Step 7 – Part 1, column C, (x)(B)Total EW, and column B, (x)(B)                 amount entered, and subcolumn (x)(C) should be blank. 
Total NYC                                                                  
                                                                                9.1.2. For each line, if the combined group did not have actual 
When you have completed column C, Part 1 and column B, Part 1, row              everywhere sales that generated a net     gain   on a combined 
b subcolumn (x)(B) for lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all        basis for the specific type of financial instrument described on 
lines 30, you must next complete, for column C, the  (x)(B) Total EW            that line, enter in column B, row b, subcolumn (x)(C), for that 
line, and for column B, the (x)(B) Total NYC line; the (x)(B) Total lines       line, the product of: the amount in column C, for that line, 
are directly below line 30-Pship. The clause (x)(B) totals are needed to        and the factor in Part 2, column B, line D. 
calculate the combined NYC aggregate MTM factor in Part 2, column          
B of this worksheet, when applicable.                                     Step 10 – Part 1, columns B and C, line 28 
                                                                           
7.1. In column C, enter in the (x)(B) Total EW line, the sum of the col-  10.1. In column B for line 28, enter the sum of the amounts from col-
     umn C, row a amounts for all lines that have an amount entered in          umn B, row b, subcolumns (x)(B) and (x)(C) for lines 10, 12, 16, 
     column B, row b, subcolumn  x(B).                                          18, 20, 21, 23, 24, 27, and all lines 30. 
                                                                           
7.2. In column B, enter in the  (x)(B) Total NYC line, the sum of the     10.2. In column C for line 28, enter the sum of the amounts from column 
     column B, row b, subcolumn (x)(B) amounts.                                 C for lines 10, 12, 16, 18, 20, 21, 23, 24, 27, and all lines 30. 
                                                                           
Step 8 – Part 2, columns B and C                                          Where are the amounts calculated on Worksheet C entered? 
                                                                           
Part 2 of the worksheet, columns B and C, compute your combined NYC       The amounts entered or calculated on Part 1, lines 10, 12, 14,16, 18, 20, 
aggregate MTM factor, which you will need in order to complete Part 1,    21, 23, 24, 27, 30, 30-Stk, and 30-Pship and Part 2, lines A, B, C, and D 
column B, for those lines which are sourced to NYC on a combined basis    are only used to compute the line 28 MTM totals in Part 1 and do not get 
under clause (x)(C) of §11-654.2(5)(a)(2).                                transferred to any other form or worksheet; the line 28 totals from Part 
                                                                          1 need to be entered on Form NYC-2.5A, Form NYC-2.5A/BC, or Work-
Never include any amounts sourced under the 8% fixed percentage method    sheet D, as follows: 
election when determining the amounts to include in the sums described     
in these step 8 instructions.                                              AMOUNT FROM WORKSHEET C     AMOUNT IS ENTERED ON 
                                                                            
8.1. Column B, line A – Enter the sum of the following amounts:            Column A completed for 
                                                                           the designated agent 
     •  the (x)(B) Total NYC amount from Part 1, column B plus the         Line 28c (NYC FDM)          Worksheet D, line 28 (NYC FDM) 
                                                                            
        amounts from Form NYC-2.5A,  lines 9 through 27, 29, and           
                                                                           Column A completed for 
        30, column D.                                                      
                                                                           each combined entity other 
8.2. Column C – Enter the sum of of the following amounts:                 than the designated agent   each entity’s Form NYC-2.5A/BC, 
                                                                           Line 28c (Total NYC FDM)    column C, line 28 (NYC FDM) 
                                                                            
     •      the (x)(B) Total EW amount from Part 1, column C plus the      
            amounts from Form NYC-2.5A,  lines 9 through 27, 29, and       Column B                    Form NYC-2.5A, column D,  
            30, column E.                                                  Line 28b (Total NYC)        line 28a (NYC) 
                                                                            
                                                                           Column C                    Form NYC-2.5A,  column E, 
8.3. Column B, line D – Divide the column B, line A amount by the          
                                                                           Line 28a (Total EW)         line 28b (EW)
     column C amount and enter the result, rounded to four decimal         
     places.                                                               
                                                                           
Step 9 – Part 1, column B, row b, subcolumn (x)(C)                         
                                                                           
9.1. Column B, subcolumn (x)(C), lines 10, 12, 16, 18, 20, 21, 23, 24,     
     27, and all lines 30, in column B, is used to compute NYC MTM         
     net gains on a combined basis, for those financial instruments de-    
     scribed on each such line, under the sourcing rules of clause (x)(C)  
     of §11-654.2(5)(a)(2). Follow the steps below to compute the sub-     
     column (x)(C) amounts.                                                
                                                                           
     Complete substeps 9.1.1 and 9.1.2 for each line (10, 12, 16, 18, 20,  
     21, 23, 24, 27, and all lines 30) for column B:                       
                                                                           
     9.1.1. For each line, if there is an amount greater than or equal to  

 Instructions for Form NYC-2.5A - 2022 Page 21

(Continued)

 Instructions for Form NYC-2.5A - 2022                                                                                              Page 22

Worksheet D – Designated agent’s NYC receipts for purposes of               For all lines involving the computation of net gains, net income, or net in-
fixed dollar minimum (FDM) tax base                                         terest, if the net amount is less than zero, enter 0. 
                                                                             
This worksheet computes the designated agent’s amount for the New York      Section 11-654.2(5)(a)(2) 
City receipts in column F. Generally, New York City receipts for purposes    
of the fixed dollar minimum tax are calculated onseparatea  company basis   For lines or section headings with a QFI box, only markXan   in the QFI box 
using the applicable allocation rule or fraction, as computed on a separate on the worksheet when the QFI box on the corresponding lines (in the case 
company basis, for each line of the worksheet.                              of lines 11 and 12) or next to the corresponding section headings on Form 
                                                                            NYC-2.5A has been marked with an X     . 
Worksheets A, B, and C of these instructions compute certain amounts         
for lines 10, 12, 21, 24, 28, and 30 of Worksheet D.                        The line numbers on Worksheet D correspond to the line numbers on 
                                                                            Form NYC-2.5A and the line numbers on Worksheets A, B, and C. Use 
Worksheets A, B, and C, and Form NYC-2.5A, column A must be com-            the corresponding line number instructions from Form NYC-2.5A, the 
pleted before you complete Worksheet D.                                     chart, and the instructions below to determine the amount to enter on 
                                                                            each line on Worksheet D. 
However, in instances where Part 2 of Worksheet C applies (i.e. when (x)(C) 
sourcing must be used), you must complete Worksheet D, lines 9 through 
27, 29, and 30, prior to completing Part 2 of Worksheet C. 
 

 Instructions for Form NYC-2.5A - 2022                                     Page 23
 
 AMOUNT    FROM               IN WORKSHEET D, ON LINE(S) 
 Worksheet A, column A 
 completed for the designated 
 agent, row f (NYC FDM), 
 for each respective line     10, 12, 21, and 24 
 Worksheet C, Part 1, 
 column A completed for the 
 designated agent, 
 line 28c (NYC FDM)           28 
 
 Worksheet B, column A 
 completed for the designated 
 agent, line 30c 
 (Total NYC FDM)              30 
 
Line 25  
Step 1: Compute the designated agent’s net interest income (not less 
than zero) from reverse repurchase agreements and securities borrow-
ing agreements. For this calculation, the designated agent’s net interest 
income is determined after the deduction of the amount of the designated 
agent’s interest expense from repurchase agreements and securities lend-
ing agreements, but cannot be less than zero. The amount of the desig-
nated agent’s interest expense to be deducted is the designated agent’s 
interest expense associated with the sum of the value of the designated 
agent’s repurchase agreements where the designated agent is the seller or 
borrower,  plus the value of the designated agent’s securities lending 
agreements where the designated agent is the securities lender; provided 
that such sum is limited to the sum of the value of the designated agent’s 
reverse repurchase agreements where the designated agent is the pur-
chaser or lender, plus the value of the designated agent’s securities bor-
rowing agreements where the designated agent is the securities borrower. 
 
Step 2: Enter 8% of the amount computed in step 1 above. 
 
For all other lines – The designated agent’s NYC  receipts amounts 
for each line should be calculated on a separate company basis using 
the applicable allocation rule or fraction as computed on a separate com-
pany basis for each such line (this includes not taking into consideration 
intercorporate eliminations). Refer to the corresponding line instructions 
for information regarding the applicable  allocation rule or fraction for 
each line. 
 
Example: For line 44 the designated agent would multiply its own sep-
arate amount of receipts from the conduct of a railroad business or a 
trucking business by a fraction, the numerator of which is the total miles 
of the designated agent within  NYC and the denominator of which is the 
total miles of the designated agent within and outside NYC. 
 
Each of the amounts calculated using Worksheet D is then entered in col-
umn F on line a of the corresponding line number.  For example, the 
amount of sales of tangible personal property on line 1 of the worksheet 
should be entered on line 1a of column F of the form.

                                                                           NYC-2.5A Instructions - 2022