On June 29, the New York City Department of Finance issued Finance Memorandum 18-6 to provide insight into the Department’s position on the New York City unincorporated business tax (UBT) issues arising with respect to the treatment of deferred income arising from the provision of services. Finance Memorandum 18-6 is generally understood to be directed at the taxability of deferred management and incentive fees earned by investment advisors and addresses the character, timing, and apportionment methodology used to determine the taxability of that deferred income.
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