New Jersey Administrative Code
Title 18 - TREASURY - TAXATION
Chapter 26 - TRANSFER INHERITANCE AND ESTATE TAX
Subchapter 4 - COMPROMISES (INHERITANCE AND ESTATE TAXES)
Section 18:26-4.1 - Domicile doubtful; terms of settlement

(a) Where the Director and taxing authorities in another jurisdiction claim that a decedent was domiciled in each respective state or jurisdiction at the time of a decedent's death and an investigation discloses a reasonable doubt regarding decedent's domicile, the Director may, in his or her discretion, enter into a written agreement with such other taxing authority and the executor, administrator, or trustee, to fix the sum acceptable to this State in full settlement of the New Jersey transfer inheritance tax; provided, that said agreement also fixes the sum acceptable to such other state or jurisdiction in full settlement of the death taxes imposable by said state or jurisdiction; and, provided further, that said agreement has the approval of the Superior Court or Tax Court of this State.

(b) Any agreement as to the decedent's domicile will provide that, if the aggregate amount payable under such agreement to all states or jurisdictions involved is less than the maximum sum allowable as a credit to the estate against the Federal estate tax imposed thereon, then the executor, administrator, or trustee must also pay to the Director so much of the difference between such aggregate amount and the amount of such credit as the amount payable to the Director under the agreement bears to such aggregate amount.

(c) Payment of the sum or sums fixed by said agreement will be accepted by the Director in full satisfaction of this State's claim for New Jersey transfer inheritance and estate tax that would otherwise be chargeable under the law.