(Tax Law, section 210-A(2)(a))
Example 1: Retail Corporation operates an online clothing store that serves the United States. Customers purchase clothing via the website and the clothing is shipped to the customer's home. Receipts from the sale of clothing shipped to locations within New York State are included in New York receipts. Receipts from the sale of clothing shipped to locations within and without New York State are included in everywhere receipts.
Example 2: Corporation A operates a car rental business in New York State and elsewhere in the United States. To keep its inventory up-to-date and make room for newer models, Corporation A sells some of its fleet of cars every year. The net gain (not less than zero) from these sales, which is properly reported as business income, shall be apportioned to New York State to the extent that the final destination of the cars sold is in New York. 100% of the net gains (not less than zero) are included in everywhere receipts. However, the amount included in New York receipts is limited to the amount included in everywhere receipts.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 4-2.1