Q&A with the Pennsylvania Department of Revenue

Is a corporation required to report the federal changes on an RCT- 101-X or RCT-128?

Jun 23, 2010
Scenario:

ABC Corp. filed a federal Form 1120 and RCT-101 for the tax year ending 12/31/06 on 4/15/07. The Department of Revenue did not settle the report prior to 1/1/08. On April 15, 2008, ABC Corp. filed a federal Form 1120-X for the tax year ending 12/31/06 which resulted in (a) an increase in federal and PA taxable income, i.e., additional tax is owed, and (b) a decrease in federal and PA taxable income, i.e., corporation is entitled to a refund. Since 4/15/08, ABC Corp. has never reported the changes on a RCT-101-X.

Q:

Assuming that the amendments to the amended report regulations have been published, is ABC Corp. required to report the federal changes on an RCT- 101-X or RCT-128?

A:

Section 406 of the Tax Reform Code as amended by Act 119-2006 provides that a Report of Change, Form RCT-128, shall be filed.

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These documents provide a summary of the answers provided by the Department of Revenue to the PICPA Committee on State Taxation at its annual question and answer session. These documents are classified as revenue information issued for informational purposes only for the convenience of PICPA members. Pursuant to 61 Pa. Code Section 3.4, these documents should not be relied upon for any purpose or used in tax appeals. Taxpayers requiring a binding opinion on their specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.