Tax insight

New Jersey mediation program for corporation business tax and sales and use tax opens October 1

Insight
5 minute read
September 10, 2025

What happened?

The New Jersey Division of Taxation (Taxation) announced on April 15 (see TB-115) that it will offer a pilot mediation program starting October 1, 2025 for resolving corporation business tax (CBT) and sales and use tax controversies. The pilot program will run for 24 months from October 1, 2025 through September 30, 2027. See also Taxation’s FAQ page, which supplements the information in TB-115.

Why is it relevant?

The mediation program is being offered as an attempt to reduce the number of protests progressing to the Conference and Appeals Branch as well as the number of complaints filed with the New Jersey Tax Court. Importantly, Taxation states that penalties and interest associated with CBT and sales and use tax controversies will be eligible for mediation.

Actions to consider

The prospect of compromising interest is a unique aspect of mediation and a potential major benefit for taxpayers. Further, this program may provide a significant opportunity to resolve difficult or large dollar audit issues for which the taxpayer or representative has been unable to achieve satisfactory resolution with audit supervisors.