New Jersey is the latest state to unveil a voluntary initiative to examine transfer pricing for taxpayers with intercompany transactions.Ā The initiative is similar to recent programs in North Carolina, Indiana, and Louisiana (see our prior coverage here and here, as well as our prior coverage of the Multistate Tax Commissionās ongoing transfer pricing collaboration and enforcement initiatives). The New Jersey Division of Taxation published guidance outlining the voluntary transfer pricing initiative last week (NJ…
Beginning November 1, 2021, the Louisiana Department of Revenue (āDepartmentā) will be offering taxpayers the opportunity to participate in a voluntary transfer pricing āmanaged auditā program (the āProgramā). Pursuant to a recently released Department information bulletin, the purpose of the Program is to: Create an efficient and expedited resolution for corporate tax audits when transfer pricing issues exist; andProvide certainty and uniformity to taxpayers on the resolution of transfer pricing issues for open audit periods…
The New York State Department of Taxation and Finance (āDepartmentā) recently published guidance stating that a nonresidentās income will be sourced to New York State unless the nonresidentās remote work location meets the ābona fide employer officeā exception to the āconvenience of the employer test.āĀ Specifically, the Department addressed a question in its FAQs regarding how to source income for Personal Income Tax purposes where a nonresidentās primary office is in New York, but the…
Two states recently unveiled transfer pricing enforcement tactics to, in their view, combat improper intercompany profit shifting.