Owning a large limited interest of a NJ co may not be enough for nexus

The fact that the major asset and revenue source of a DE company was a limited interest in a NJ company did not mean that the DE company owed the NJ corporate business tax. The 2 companies had some common board members but otherwise were not at all integrated or unitary. Even though the court ruled in favor of the taxpayer in this case it is worth keeping in mind that this might not be the best structural set-up because who wants to wind up in NJ tax court? **shudder**