The New York State Department of Taxation and Finance issued an Advisory Opinion finding that a corporate partner may aggregate the activities and employees of two majority-owned partnerships, and other single member limited liability companies (“SMLLCs”) directly or indirectly owned, for purposes of satisfying the “principally used” and “employment” tests for the New York State Investment Tax Credit (“ITC”). Advisory Opinion, TSB-A-16(1)C (N.Y.S. Dep’t of Taxation & Fin., Jan. 11, 2016). The Department found, first, that the Petitioner corporation, while not itself a registered broker dealer, was entitled to such treatment based on the broker-dealer status of the partnerships and SMLLCs that it owned and thus qualified for the ITC available to broker dealers under Tax Law § 210(12)(b)(i). The Petitioner also was considered to have purchased the property placed in service by a partnership it owned for purposes of qualifying for the ITC under the aggregate principle. Finally, the Petitioner was permitted to aggregate the property and activities of the employees of two SMLLCs, to the extent they were qualifying uses under the ITC statute, to satisfy one of the three employment tests in the statute.