Side-by-side at $1,000,000 qualified income, 37% bracket
| Field | New York | Massachusetts |
|---|---|---|
| Statute | N.Y. Tax Law Article 24-A (§§ 860-866) | Mass. Gen. Laws c. 63D §§ 1–7 (Elective Pass-Through Entity Excise) |
| Election deadline | Annual election made on or after January 1 and no later than March 15 of the tax year for which the election is made (postponed to next business day if March 15 is a weekend/holiday). Quarterly estimated payments due March 15, June 15, September 15, and December 15. | Annual election made on a timely-filed Form 63D-ELT (filed with Form 355S, Form 3, or Form 2 as applicable) on or before the due date including extensions. Cannot be made on an amended return. |
| Rate | 6.85% to 10.90% (4 graduated brackets) | 5.00% flat |
| Owner credit | refundable | refundable |
| Composite interaction | stacks | stacks |
| §199A QBI reduction | Yes | Yes |
| Last verified | 2026-05-11 | 2026-05-11 |
Reference federal-arbitrage computation
Both scenarios assume $1,000,000 qualified net income, a 37% owner federal bracket, and no apportionment. Both reduce §199A QBI base proportionally; net benefit shown is the federal SALT-arbitrage less the rough QBI offset (~20% × bracket × entity tax).
Entity-level tax: $68,500. Net of QBI offset (~$5,069): $20,276.
Entity-level tax: $50,000. Net of QBI offset (~$3,700): $14,800.
Why owners with K-1 income across these two states care
New York and Massachusetts interact in three ways that matter to a multi-state K-1 holder: (1) independent elections — each state's PTET is its own election with its own deadline and form, so a missed NY deadline does not affect MA; (2) aggregate federal deduction — the entity-level tax paid to BOTH states is deductible at the federal entity level under IRS Notice 2020-75, so the federal arbitrage compounds; (3) composite-return interaction may differ — see each state's row above.
Run the multi-state picker pre-filled with both jurisdictions: