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.)

The starting point for computing a taxpayer’s CBT is federal taxable income before the net operating loss deduction and special […]

As anticipated, today’s federal budget (Budget 2018) focuses on a few targeted areas, including the taxation of passive investments made by private corporations, and does not contain any measures in response to the enactment of tax reform in the United States or relating to the OECD BEPS initiative. Significantly, Budget 2018 substantially narrows the scope of the Department of Finance’s 2017 passive investment proposals. The 2017 proposals were exceedingly complex, and effectively proposed a […]