ARTICLE
19 December 2018

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

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The Tax Court of New Jersey released a published decision in ADP Vehicle Registration, Inc. v. Director, Division of Taxation on December 11, 2018.
United States Tax

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.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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