Reed Smith Client Alerts

In a decision released today, the Tax Court of New Jersey ruled that a foreign corporation was not subject to New Jersey corporation business tax (“CBT”) on its income from sources outside the United States. A copy of the decision, Infosys Limited of India, Inc,1 is available here.
Statue of Justice

Background and Decision

Infosys is a multinational corporation headquartered and incorporated in India. It performed IT services in New Jersey and reported its CBT by including its worldwide income in the tax base. Infosys subsequently amended its CBT-100 returns to exclude its foreign-source income. (That income was not subject to federal income tax under the U.S.-India tax treaty.)