New Jersey 2021 Combined Reporting Initiative

Thoughtware Alert Published: Jun 28, 2021
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Beginning June 15, 2021, and running through October 15, 2021, companies that have had nexus with New Jersey prior to filing as part of a combined return will have the opportunity to voluntarily come forward and comply with the corporation business tax filing requirements. New Jersey is seeking companies that have been included as part of a combined group filing and indicated they have nexus with New Jersey but have not filed as a separate entity for periods prior to 2019. 

These companies are not eligible for a standard voluntary disclosure agreement; however, the Department of Revenue will consider entering into a closing agreement with approved companies based on the following:

  • Companies must not have been incorporated in New Jersey, authorized to do business in New Jersey, or registered for the corporation business tax prior to being included as part of a 2019 or 2020 combined return
  • The taxpayer must provide the New Jersey registration number of the Managerial Member, which begins with NU
  • The lookback period will be limited to the periods ending after June 30, 2016, or the date nexus was established with New Jersey, whichever is later; returns for prior periods will not be required
  • The taxpayer must file all required returns and remit payment of the reported tax liability in full within 45 days of execution of the agreement
  • The Division of Taxation will waive all penalties
  • The taxpayer will remit payment of interest within 30 days of assessment
  • All returns will be subject to routine audits

Failure to take advantage of this initiative will result in the lookback period going beyond return periods ending after June 30, 2016, and all applicable penalties and interest being assessed. 

For more information, reach out to your BKD Trusted Advisor™ or submit the Contact Us form below. 

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