This office lease provision states that it is an unpermitted assignment for partners to have a change in their share of partnership ownership and thus a default under the lease. Generally, this type of change in ownership is couched in those provisions dealing with changes in share ownerships of corporations.
New Jersey Provision Dealing with Changes in Share Ownership of Corporations and Changes in Share Ownership of Partnership
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§163(j). A combined return for New Jersey Corporation Business Tax purposes is treated as one return and taxpayers should make adjustments applying the I.R.C. §163(j) limitation as though they had been included on a single federal consolidated return.
174, research and experimental expenditures may be treated as expenses and deducted currently or, at the election of the taxpayer, may be amortized over a period of not less than 60 months, beginning with the month in which the taxpayer first realizes benefits from the expenditures.
As for conformity to the Internal Revenue Code, approximately 35 states currently adopt section 163(j) for purposes of their corporate income taxes. That conformity, however, is far from uniform.
The section 163(j) limitation is applied at the partnership level. As provided in Q/A 1, the amount of deductible business interest expense in a taxable year cannot exceed the sum of the partnership's business interest income, 30% of the partnership's ATI, and the partnership's floor plan financing interest expense.
Investment interest expense incurred by a partner to acquire a partnership interest can be deducted from distributive share of partnership income. New Jersey residents can deduct the full amount of qualified unreimbursed business expenses from their distributive share of partnership income.
The Shareholder Jurisdictional Consent is the shareholders' acknowledgement that New Jersey has the jurisdiction (right) to tax each shareholder's S corporation income, regardless of the shareholder's residency.
Welcome to the New Jersey Opportunity Zones Reinvested capital gains are deferred from taxation until exit from a Qualified Opportunity Fund or December 31, 2026, whichever comes first.
INSTRUCTIONS FOR FORM CBT-2553-R This form is to be used by a currently authorized corporation electing New Jersey S corporation status effective retroactively to a prior return period. Submit a copy of the original CBT-2553 if previously approved.
