«The business tax reform component also includes a merger of the state's corporate franchise tax and bank tax, which will extend income
apportionment methodologies that benefit businesses with significant jobs and capital investments in New York state.
Whether
the apportionment methodology is on a fair and reasonable basis will depend on the facts and circumstances of each case.
For the purposes of
the apportionment methodology, it would be reasonable to adjust the 30 June 2018 value of Ram's superannuation interest in the retirement phase ($ 400,000) by $ 200,000.