Market-Based Sourcing Applied to Service Fees in New Jersey

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Overview


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.