Curious if other NJ people have come to a strong conclusion on how to calculate COJ with respect a NJ resident partner who is subject to CT PTE Tax. The partnership reports it to the partner in two pieces:
1. The share of income reported at the entity-level and resulting allocable share of tax paid at the entity-level
2. The taxable income reported on the partner's behalf on the composite return. In this case, composite income is more than double the share of PTE income allocated. The composite tax liability is very low because a large percentage (87.5) of the PTE tax is applied as a credit toward the individual composite tax.
From my read, NJ does state that because NJ does not tax partnerships, a tax paid at the entity-level is available for credit by the partner.
I also am fairly familiar with how to handle taxation by multiple jurisdictions within a state on different amounts of income (i.e. NY State, UBT, MCTMT or PA, Philly BIRT/NPT, etc.). In this case, though, there are two taxes being assessed on different amounts of income by the same jurisdiction. I have not been able to find any clear guidance on this.
Do I just report the higher income amount and total tax as if it's one item? Input one of them as if it was a local jurisdiction within the State?
I appreciate any thoughts or input!