Chapter 56 of the laws of 2011 reduced the Article 9-A tax rates for “eligible qualified New York manufacturers” for taxable years beginning on or after January 1, 2012 and before January 1, 2015. For a qualifying manufacturer, the tax rate on entire net income is reduced from 6.5% to 3.25%. The Department has now issued a Technical Memorandum setting forth the criteria for classification as an eligible qualified New York manufacturer. Article 9-A Tax Rates for Eligible Qualified New York Manufacturers, TSB-M-13(1)C (N.Y.S. Dep’t of Taxation & Fin., Jan. 8, 2013). One of the criteria discussed is a “property test,” which requires that the taxpayer have tangible property in the State principally used in the production of goods, and either (i) the adjusted basis of that property for federal income tax purposes is at least $1 million or (ii) all of the taxpayer’s real and personal property is located in the State.