120.5 S corporation shareholders.

Tax Law, § 620(d) For a shareholder of an S corporation, the term income tax in section 120.1(a) of this Part does not include any tax imposed upon or paid by the corporation, but does include any such tax imposed upon or payable by the shareholder to another jurisdiction calculated on the income of the corporation, regardless of whether the corporation is an S corporation in the other state by virtue of a separate state election or in conformity with the Federal election.