New Jersey partnership question.

Partnerships need to use market sourcing for purposes of calculating NR withholding tax (though NJ doesn't even call this withholding anymore).

However, for purposes of calculating the NJ distributive share of income, you apply Gross Income Tax (personal income tax) rules, which is 3 factor and includes COP.

If I end up with 0% apportionment under GIT and 10% apportionment under CBT (withholding tax), the partnership pays tax upfront but NRs get 100% refund?

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