BIS LP, Inc. v. Director, Division of Taxation

This case returns to us after our limited remand in BIS LP, Inc. v. Director, Division of Taxation, 26 N.J.Tax 489, 501-02 (App.Div.2011). Plaintiff BIS LP, Inc. (BIS) filed a New Jersey corporation business tax (CBT) return electing to be taxed as an investment company. BIS reported income it received from BI-SYS Information Solutions L.P. (Solutions), in which BIS maintained a ninety-nine percent limited partnership interest. After the Director disallowed BIS’s election as an investment company, BIS contended it owed no tax and sought a refund of the $1,480,524 in tax it previously reported…