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State Tax Practice Focused on Foreign Source Income; Criminal & Civil Enforcement

The expanding global economy has increased state taxation of business enterprises that conduct operations on an international level. These business taxpayers are subject to taxation in multiple jurisdictions with diverse laws that have few shared relevant substantive provisions. The U.S. Constitution...

State Tax Practice Focused on Foreign Source Income; Criminal & Civil Enforcement

The expanding global economy has increased state taxation of business enterprises that conduct operations on an international level. These business taxpayers are subject to taxation in multiple jurisdictions with diverse laws that have few shared relevant substantive provisions. The U.S. Constitution...

New Jersey Tax Court Refuses to Tax Foreign Income: IBM v. Director

By Peter Faber and Leah Robinson On January 26, 2011, the New Jersey Tax Court agreed with IBM that foreign source income excluded from federal taxable income is also excluded from New Jersey entire net income. Taxpayers should consider filing refund claims. On January 26, 2011, the New Jersey Tax...

Distinctions Between State and Federal Taxation of Foreign Source Income

By Suellen M. Wolfe, LL.M., CPA The federal Internal Revenue Code provides that foreign corporations are subject to U.S. income tax on certain foreign source income that is "effectively connected" with a U.S. trade or business. Jurisdiction to subject the foreign corporation to U.S. income...