The New Jersey Superior Court, Appellate Division upheld the application of New Jersey’s 2020 amendment to its royalty addback regulation retroactively to tax years prior to the regulation’s amendment. In 2020, New Jersey amended its regulation (N.J. Admin. Code § 18:7-5.18) to delete geographical limitations in the addback exception for royalty payments made to a
New Jersey couple not required to include Section 965 amounts in New Jersey income
The New Jersey Tax Court determined that a New Jersey-based couple was not required to include Section 965 amounts in New Jersey income, as deemed repatriated dividends are not subject to the New Jersey Gross Income Tax (GIT), New Jersey’s personal income tax.
The taxpayers owned several interests in controlled foreign corporations (CFCs) and in
Third Circuit holds that principles of comity bar Federal Court challenge to New Jersey’s partnership filing fee
The Third Circuit Court of Appeals upheld a District Court’s dismissal of a taxpayer’s challenge to New Jersey’s partnership filing fee under the tax comity doctrine. The partnership filing fee was enacted by New Jersey in 2002 to offset the costs of reviewing and auditing partnership tax returns. The fee is a flat fee computed
Cultivating a business-friendly environment in the Garden State
This week on the SALT Shaker Podcast, Eversheds Sutherland Associate Jeremy Gove welcomes Chris Emigholz, Chief Government Affairs Officer at the New Jersey Business & Industry Association (NJBIA), to the show.
First, they cover Chris’ role at NJBIA and what NJBIA does for New Jersey taxpayers. They then dive into a meaty tax discussion
New Jersey Division of Taxation hints at possible cloud computing tax
A recent report issued by the New Jersey Division of Taxation includes a suggestion that state lawmakers consider a cloud computing tax. The report titled, “Studying the Impact of the Digital Economy” recommends adopting a sales and use tax model that differentiates between physical good and services and digital goods and services. The report notes
COST’s Mid-Atlantic Regional State Tax Seminar
- Discussion of State Tax Cases, Issues & Policy Matters to Watch – Jeff Friedman and Jeremy Gove
- Practical Considerations for Handling Tax Controversies
New Jersey updates guidance regarding virtual currencies
The New Jersey Division of Taxation recently updated Technical Advice Memorandum 2015-1(R), first issued in 2015, regarding the tax treatment of transactions involving convertible virtual currency, such as Bitcoin. The updated TAM states that the state conforms to the federal treatment of convertible virtual currency for Corporation Income Tax and Gross Income Tax purposes.
SALT partners to present for New England, New Jersey conferences this week
This week, Eversheds Sutherland is a proud sponsor of the virtual New England State and Local Tax Forum. Partner Breen Schiller will cover key issues facing combined filers in 2021.
In addition, Partner Jeff Friedman will present a virtual multistate tax update during the New Jersey Society of Certified Public Accountants Multistate Tax Conference
Multistate Tax Commission adopts updated P.L. 86-272 guidance
The Multistate Tax Commission (MTC) adopted its long-awaited guidance interpreting Public Law (P.L.) 86-272 protections for internet businesses on August 4, 2021. P.L. 86-272 was passed by the U.S. Congress in 1959, and protects businesses from the imposition of state income tax when the business’s only activity in the state is the solicitation of orders
Legal Alert: New Jersey to restore pre-pandemic nexus standards
On August 3, 2021, the New Jersey Division of Taxation released guidance on its website informing taxpayers that as of October 1, 2021, the state is ending its temporary waiver of certain corporation business tax (CBT) and sales tax nexus standards necessitated by the COVID-19 pandemic. The temporary guidance allowing employers to source wage income
On July 14, Eversheds Sutherland attorneys Jeff Friedman, Ted Friedman, Liz Cha, Jeremy Gove and Chelsea Marmor will lead panels for COST’s Mid-Atlantic Regional State Tax Seminar.
Panel details and speakers include: