The Department of Taxation and Finance has ruled that an unauthorized foreign non-life insurance corporation, which writes surplus lines policies for property and casualty insurance risks through licensed excess lines brokers in New York, is subject to tax under Tax Law § 1501(a) (Article 33 tax), and not under Tax Law § 1502-a (a tax on premiums applicable only to authorized insurers), for tax periods beginning after 2002. Advisory Opinion, TSB-A-16(4)C and TSB-A-16(5)C (N.Y.S. Dep’t of Taxation & Fin., June 10, 2016). Therefore, the unauthorized non-life insurance corporation must compute its tax on the highest of four alternative tax bases, plus a tax on allocated subsidiary capital. The Department specifically concluded that this did not result in “double taxation” of premiums as between the premiums tax on excess lines brokers and the tax on the unauthorized insurance company.