1. (a) subsidiary capital (capital invested in subsidiaries) and the income therefrom;
2. (b) investment capital and investment income (see section 3-3.2 of this Part—Definition of investment capital and section 4-8.3 of this Title—Definition of investment income); and
3. (c) business capital and business income (all capital other than subsidiary capital and investment capital, and all income other than investment income and income from subsidiary capital).

Tax Law, §§ 208(9), 210(1)

For purposes of computing the tax imposed by article 9-A of the Tax Law, every corporation is treated as a holding corporation to the extent that it holds investments in subsidiaries, as an investment trust to the extent that it holds other securities, and as a business corporation to the extent that it is engaged in ordinary business. In the case of every such corporation, article 9-A of the Tax Law defines and treats differently: