Article 32 of the Tax Law imposes a franchise tax on every banking corporation, as defined in section 16-2.5 of this Part, for the privilege of exercising its corporate franchise or of doing business in New York State in a corporate or organized capacity for all or any part of each of its fiscal or calendar years. (See Subpart 16-3 of this Part - Corporations Subject to Tax.) Also, certain corporations, including bank holding companies, are required or in the discretion of the Tax Commission may be required or permitted to make a combined return with related corporations taxable under article 32 of the Tax Law. (See Subpart 21-2 of this Title - Combined Returns.)