New Jersey Division of Taxation: State not bound by advance pricing agreements with IRS

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The New Jersey Division of Taxation has issued a technical advisory memorandum (TAM), which it intends to codify in a regulation, stating that while it will "take into consideration" an advance pricing agreement (APA) between a taxpayer and the IRS in evaluating the appropriateness of intercompany pricing, it is not bound by such APAs and may use other criteria in determining a "fair and reasonable tax" under New Jersey law. [New Jersey Division of Taxation, TAM-17, 6/6/2011]


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