Market-Based Sourcing Applied to Service Fees in New Jersey



Alysse McLoughlin and Kathleen M. Quinn wrote this bylined article discussing the New Jersey Tax Court’s Bank of America decision. “Even though the Legislature has not adopted market-based sourcing, this decision improperly opens the door for the [Division of Taxation] to employ market-based sourcing principles to source all types of receipts from services to New Jersey, even when those services are performed outside the state,” the authors wrote.