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INTERN. BUSINESS MACHINES CORP. v. DIR. DIV. OF TAX.

Docket No. 011630-2008, DOCKET NO. 011795-2009

26 N.J. Tax 102 (2011)

INTERNATIONAL BUSINESS MACHINES CORPORATION, Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. CRESTRON ELECTRONICS, INC., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant.

Tax Court of New Jersey.

January 26, 2011.

Attorney(s) appearing for the Case

Peter L. Faber of the New York bar, admitted pro hac vice, and Leah Samit Robinson, for plaintiff International Business Machines Corporation (McDermott Will & Emery, LLP, attorneys).

Paul H. Frankel and Mitchell A. Newmark, for plaintiff Crestron Electronics, Inc. (Morrison & Foerster, LLP, attorneys).

Marlene G. Brown and Michael J. Duffy, for defendant (Paula T. Dow, Attorney General of New Jersey, attorney).

DeALMEIDA, P.J.T.C.

The question before the court is whether, during the period at issue, a corporation's entire net income for New Jersey corporation business tax ("CBT") purposes included the taxpayer's extra-territorial income as that term was defined in I.R.C. § 114(e). For the reasons explained more fully below, the court concludes that New Jersey law couples a corporation's entire net income for CBT purposes to its federal taxable income as defined...

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