N.Y. Tax Law § 25
* § 25. Disclosure of certain transactions and related information. (a)** (1) Every taxpayer, or person as defined in section seven thousand seven hundred one of the internal revenue code, required to file a disclosure statement with the internal revenue service pursuant to section six thousand eleven of the internal revenue code, or the regulations promulgated thereunder, related to a reportable transaction or a listed transaction, as those terms are defined in such section or regulations, must attach a duplicate of such disclosure statement to the return or report required to be filed by such taxpayer or person for the taxable year under article nine, nine-A, twenty-two, thirty-two or thirty-three of this chapter, and provide such other information related to such disclosure as prescribed by the commissioner. Such disclosure shall be made notwithstanding that one member of an affiliated group, as defined by section fifteen hundred four of the internal revenue code, may file such disclosure statement with the internal revenue service on behalf of its affiliates including such taxpayer or person. ** NB Effective until January 1, 2015 ** (1) Every taxpayer, or person as defined in section seven thousand seven hundred one of the internal revenue code, required to file a disclosure statement with the internal revenue service pursuant to section six thousand eleven of the internal revenue code, or the regulations promulgated thereunder, related to a reportable transaction or a listed transaction, as those terms are defined in such section or regulations, must attach a duplicate of such disclosure statement to the return or report required to be filed by such taxpayer or person for the taxable year under article nine, nine-A, twenty-two or thirty-three of this chapter, and provide such other information related to such disclosure as prescribed by the commissioner. Such disclosure shall be made notwithstanding that one member of an affiliated group, as defined by section fifteen hundred four of the internal revenue code, may file such disclosure statement with the internal revenue service on behalf of its affiliates including such taxpayer or person. ** NB Effective January 1, 2015 ** (2) Every taxpayer or such person who participates in a New York reportable transaction for a taxable year must disclose such participation with its return or report required to be filed under article nine, nine-A, twenty-two, thirty-two or thirty-three of this chapter for the taxable year in a form prescribed by the commissioner, and provide such other information related to such transaction as prescribed by the commissioner. A New York reportable transaction is a transaction that has the potential to be a tax avoidance transaction as determined by the commissioner. ** NB Effective until January 1, 2015 ** (2) Every taxpayer or such person who participates in a New York reportable transaction for a taxable year must disclose such participation with its return or report required to be filed under article nine, nine-A, twenty-two or thirty-three of this chapter for the taxable year in a form prescribed by the commissioner, and provide such other information related to such transaction as prescribed by the commissioner. A New York reportable transaction is a transaction that has the potential to be a tax avoidance transaction as determined by the commissioner. ** NB Effective January 1, 2015
(4) Provided the commissioner has prescribed regulations pursuant to paragraph three of this subdivision the commissioner is authorized to designate specific transactions that are the same as, or substantially similar to, transactions that the commissioner has determined to be tax avoidance transactions. The provisions of article two of the state administrative procedure act shall not apply to the designation of a specific transaction as a tax avoidance transaction; provided, however, that the commissioner shall designate any such transaction by notice or other form of published guidance. (b)(1) Every person required to make and file a statement or return pursuant to section six thousand one hundred eleven of the internal revenue code must file a duplicate of such statement or return, including all documentation submitted to the internal revenue service in connection with such statement or return, with the commissioner if any of the following conditions apply:
(2) Such duplicate statement or return must be filed within sixty days of the later of: