A-6262-06T3
12-15-08
In administering N.J.S.A. 54:10A-2, a section of the Corporation Business Tax Act, the Director may not give retroactive application to the clarifying example in N.J.A.C. 18:7-1.9(b), i.e., to tax years antedating the promulgation in 1996 of the clarifying example dealing with the tax liability of foreign corporations that earn licensing fees from parent corporations in New Jersey.