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In a recent letter submitted to state Taxation officials, the NJBIA/NJ Chamber Joint Taxation & Economic Development Policy Commitee offered suggestions to improve draft rules that implement revenue-neutral legislative changes made last year to the Corporation Business Tax. 

 The Joint Committee’s comments in an April 19 letter on the proposed regulatory changes reflect the insights of the corporate taxpayer members of NJBIA, the State Chamber of Commerce, and many of the tax professionals that work for New Jersey corporations. 

 The Division of Taxation “did an excellent job adhering to what the statute called for and not deviating from or exceeding current law,” the Joint Committee wrote in the letter.  “That being said, there are several areas where our Joint Committee has recommendations that can hopefully improve these draft regulations for both the taxpayers and (the Division of) Taxation.” 

 The most significant changes made under the 2023 law affecting Global Intangible Low-Taxed Income (GILTI) and Net Operating Losses (NOLs) are not discussed in the letter because the draft rules closely follow the statute. Instead, the letter makes recommendations on various technical aspects of the draft regulations and substantive policy suggestions related to R&D deductibility, as well as the definition of “reasonable approximation” for purposes of sourcing services receipts. 

 To read the entire letter from the NJBIA/Chamber Joint Taxation & Economic Development Policy Committee, go here.