NJ Apportionment Formula Includes Foreign-Derived Income
Law360 (August 23, 2019, 7:47 PM EDT) -- New Jersey will include net global intangible low-taxed income and foreign-derived intangible income in the apportionment factor used for business income, with the income subject to a new formula that has drawn requests for clarification, according to recently released guidance.
The “net amount of GILTI and the net FDII amounts” will be included in the denominator of the state's apportionment factor as well as the numerator, “if applicable,” according to Technical Bulletin TB-92, released Thursday by the New Jersey Division of Taxation. The two types of income will be sourced under the “all other business receipts” category, according to the bulletin....
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