A Critique of New Jersey’s Guidance on Passthrough Income Sourcing

Mike Puzyk, a partner in our Tax and Benefits team, takes a closer look at the New Jersey Division of Taxation’s stance in TB-112(R) on how N.J. Stat. Ann. Section 54A:5-19 applies to passthrough entities. He argues that the Division’s interpretation seems to conflict with both the clear wording of the statute and its intended legislative purpose.