Interest paid to a non-resident individual pursuant to an installment note received from the individual’s sale of stock in a New York S corporation is not income from property employed in a trade or business carried on in New York and is not subject to New York State personal income tax. Advisory Opinion, TSB-A-15(5)I (N.Y.S. Dep’t of Taxation & Fin., May 29, 2015). However, if the conditions of Tax Law § 631(b)(1)(A)(1) are met (the S corporation owns New York realty having a fair market value of at least 50% of the value of all the assets of the C corporation owned for at least two years before the stock sale), a portion of the gain included in the principal payments on the installment note would be attributable to the real property and would be considered New York-source income subject to tax by the nonresident individual.