The issue

The Pennsylvania Department of Revenue (DOR) released its regulatory agenda for 2026.

Sales Factor Sourcing Sales of Services

Under Section 6 of the Fiscal Code and Section 401 of the Tax Reform Code, the DOR proposes adding Section 153.26a on sales factor sourcing for services. Act 52 of 2013 revised the method for sourcing service revenue in corporate net income tax (CNIT) calculations. The proposed rule establishes procedures for sourcing service income, apportioning business income to Pennsylvania, and ensuring uniform application by taxpayers.

• PICPA Comment Letter to DOR on Corporate Tax Bulletin - Sourcing of Sales of Intangibles - June 30, 2023

Business Income and Nonbusiness Income

Under Section 6 of the Fiscal Code and Section 401 of the Tax Reform Code (72 P.S. Section 7401(3)), the DOR is amending CNIT regulations by adding Section 153.24a on business and nonbusiness income. It reflects legislative changes and evolving case law on states’ taxation of corporations under the Unitary Business Principle.

• PICPA Comments on Proposed Reg #15-462, Business and Nonbusiness Income - June 20, 2024

Payment Methods for Obligations Due the Commonwealth

Under Section 9 of the Fiscal Code, the DOR and Treasury propose a full revision of Chapter 5 on payment methods for obligations due the Commonwealth. The rule updates allowable payment methods - including cash, check, and various electronic funds transfer (EFT) options - specifies which obligations must be paid by EFT, and outlines penalties for noncompliance.

• PICPA Comments on Proposed IRRC Reg. #15-463, Payment Methods for Obligations Due - June 17, 2024
• PICPA Comments: Final-Form Reg. #15-463 Payment Methods for Obligations Due the Commonwealth - May 26, 2026

Reviewed June 2026