Q&A with the Pennsylvania Department of Revenue

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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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.