[ajiang]

Ok, not really helpful.

You can't. The point of this program is to bring jobs to New york. You need to develop a forecast of new jobs your startup would bring to New York, which gets reported and reviewed on a regular basis. The penalties for not meeting those forecasts would be determined by your sponsoring university, which can include losing your tax free status for a year or getting kicked out of the program.

The regulations around this program aren't particularly onerous from reading the regulations document. You need to establish an understanding with a sponsoring university that your company will both benefit the community, the school's academic mission, and bring new jobs to New York. There are some reporting requirements, but that seems like a paltry ask compared to ~40-50% tax savings on profit and no income tax.