1. (1) Article 32 of the Tax Law provides for distinct allocations of entire net income, alternative entire net income and taxable assets. Entire net income is defined in section 18-2.2 of this Title. Alternative entire net income is defined in subdivision (b) of section 18-4.1 of this Title. Taxable assets are defined in section 18-5.2 of this Title. A corporation subject to article 32 of the Tax Law which has entire net income derived from business carried on both within and without New York State shall determine the portion of its entire net income which is derived from business carried on within New York State pursuant to Subpart 19-2 of this Part. A corporation subject to article 32 of the Tax Law which has alternative entire net income derived from business carried on both within and without New York State shall determine the portion of its alternative entire net income which is derived from business carried on within New York State pursuant to Subpart 19-3 of this Part. A corporation subject to article 32 of the Tax Law which has taxable assets derived from business carried on both within and without New York State shall determine the portion of its taxable assets derived from business carried on within New York State pursuant to Subpart 19-4 of this Part. Except as provided in paragraph (2) of this subdivision, a corporation subject to article 32 of the Tax Law which does not have entire net income, alternative entire net income or taxable assets derived from business carried on without New York State must allocate such entire net income, alternative entire net income or taxable assets 100 percent to New York State.
2. (2) A taxpayer which has established an IBF as defined in section 16-2.16 of this Title may, in lieu of modifying its entire net income by deducting therefrom the adjusted eligible net income of the IBF (in the case of a loss, such loss must be added to entire net income), elect on an annual basis, pursuant to subdivision (c) of section 19-2.3 of this Part, to reflect the results of its IBF operations in its entire net income allocation percentage and its alternative entire net income allocation percentage. When the taxpayer makes such election, such taxpayer is entitled to allocate its entire net income and alternative entire net income within and without New York State pursuant to Subparts 19-2 and 19-3 of this Part, respectively.
3. (b) When a corporation subject to article 32 of the Tax Law carries on business within and without New York State for only part of the taxable year, it allocates entire net income, alternative entire net income or taxable assets within and without New York State for only that part of the taxable year during which it carries on such business within and without New York State. For allocation of entire net income for a short period, see section 19-8.1 of this Part. For allocation of alternative entire net income for a short period, see section 19-8.2 of this Part. For allocation of taxable assets for a short period, see section 19-8.3 of this Part.
4. (c) For purposes of this Part, the phrase business carried on means “doing business” as defined in section 16-2.7 of this Title, provided the income or expenses from such business are required to be included in the computation of the taxpayer's alternative entire net income.

Tax Law, § 1454

(a)