Legal Opinion
International Business Machines Corp. v. Director
New Jersey Tax Court
Decided January 26, 2011PublishedCited by 5 opinions
1Opinion of the Court
DeALMEIDA, P.J.T.C.
The question before the court is whether, during the period at issue, a corporation’s entire net income for New Jersey corporation business tax (“CBT”) purposes included the taxpayer’s extraterritorial income as that term was defined in I.R.C. § 114(e). For the reasons explained more fully below, the court concludes that New Jersey law couples a corporation’s entire net income for CBT purposes to its federal taxable income as defined by federal law with limited exceptions. Because federal law excluded extraterritorial income from federal taxable income during the period at…
2Cases cited33 opinions
- Brill v. Guardian Life Insurance Co. of AmericaSupreme Court of New Jersey · 1995
- Metromedia, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 1984
- Peper v. Princeton University Board of TrusteesSupreme Court of New Jersey · 1978
- Merin v. MaglakiSupreme Court of New Jersey · 1992
- GE Solid State, Inc v. Director, Division of TaxationSupreme Court of New Jersey · 1993
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3Cited by5 opinions
- Wellington v. Township of HillsboroughNew Jersey Tax Court · 2012
- Beljakovic v. DirectorNew Jersey Tax Court · 2012
- Murphy v. DirectorNew Jersey Tax Court · 2012
- Duke Energy Corp. v. Director, Division of TaxationNew Jersey Tax Court · 2014
- Toyota Motor Credit Corp. v. Director, Division of TaxationNew Jersey Tax Court · 2014