Would the economic nexus be sufficient to subject a corporation to the CNIT and/or CSFT?
During a recent meeting with the Philadelphia Bar Association SALT Committee, the Acting Chief Counsel indicated that the economic nexus would be sufficient to subject a corporation to the CNIT and/or CSFT. Please confirm whether her comment reflects a change in longstanding Department of Revenue policy. Please provide examples where economic nexus will create nexus.
The Department interprets the statutes of the Commonwealth to allow taxation to the limits of the United States Constitution. There is no change in the policy of the Department.