What is the DOR's position regarding IRC Sec. 108?

Jun 30, 2011

What is the Department's position regarding IRC Sec. 108, specifically:

1) Is the exclusion of income recognized for federal tax purposes on a pre- or post-apportioned basis?

2) Are taxpayers required to reduce PA tax attributes (e.g., PA NOL’s)?


There is no statutory authority to adjust Federal taxable income for this item in computing Pennsylvania taxable income. There is also no authority to adjust Pennsylvania tax attributes for this item.
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