New Jersey – Out-of-state limited partner subject to CBT

A New Jersey tax court found that the corporate limited partner of a New Jersey limited partnership was subject to the state’s Corporation Business Tax. The reasons for the corporate partner’s nexus included: (1) the partner and limited partnership were in the same line of business; (2) they were both parties to the same New Jersey-governed cash management agreement; (3) they had common agents, managers, officers, and directors; and (4) they shared a principal place of business in New Jersey.

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