N.Y. Tax Law § 1177: Limited binding and beneficial effect

§ 1177. Limited binding and beneficial effect. (a) The agreement

authorized by this article binds and inures only to the benefit of New

York state and the other member states. No person, other than a member

state, is an intended beneficiary of the agreement. Any benefit to a

person other than a state is established by the laws of New York state

and the other member states and not by the terms of the agreement.

(b) Consistent with subdivision (a) of this section, no person shall

have any cause of action or defense under the agreement or by virtue of

New York state's approval of the agreement. No person may challenge, in

any action brought under any provision of law, any action or inaction by

any department, agency, or other instrumentality of New York state, or

any political subdivision of New York state on the ground that the

action or inaction is inconsistent with the agreement.

(c) No law of New York state, or the application thereof, may be

declared invalid as to any person or circumstance on the ground that the

provision or application is inconsistent with the agreement.