Q&A with the Pennsylvania Department of Revenue

Scenario: A corporation reports and remits a self-assessed CNIT.

Jun 30, 2011
Scenario:

On its 2008 RCT-101 filed on 4/15/09, ABC Corp. reports and remits a self-assessed CNI Tax in the amount of $100. As a result of the receipt of an RAR on 4/1/11, ABC Corp. filed a RCT-128C on 4/15/11 resulting in a reduction of 2008 CNI Tax. ABC Corp. requested that the $20 overpayment of 2008 CNI Tax be credited to the corporation’s
2009 CNI Tax to satisfy a deficiency.

Q:

For purposes of determining whether any interest is due on the 2009 payment, does the Department of Revenue treat the $20 payment as being made on 4/15/09 or 4/15/11?

A:

In the above example the Bureau of Corporation Taxes would identify the date associated to the $20 overpayment that developed from the filing of the RCT-128C as 4/15/09. The due date for the 2009 tax deficiency is 4/15/10. Since the date associated to the overpayment is prior to the due date for the 2009 tax year, no interest would be charged on the application of the overpayment credit.

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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.