Client Alert

New Jersey Tax Court Upholds Taxpayer’s Three-Factor Apportionment Formula

13 Dec 2018

The Tax Court of New Jersey released a published decision in ADP Vehicle Registration, Inc. v. Director, Division of Taxation on December 11, 2018. The Tax Court’s precedential decision rejected New Jersey’s attempts to allocate 100% of the income of ADP Vehicle Registration, Inc. (“ADPVR”) to New Jersey, holding instead that only approximately 2% of ADPVR’s business was attributable to New Jersey. The Tax Court found that ADPVR maintained a regular place of business outside of New Jersey through its unitary ownership interest in Computerized Vehicle Registration (“CVR”), a partnership headquartered in California, and agreed with ADPVR that the undisputed evidence objectively established that CVR maintained a bona fide office in California that was staffed with over 60 workers who regularly conducted CVR’s business.

Read a copy of the decision.



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