We provide here a written summary of answers provided by the Department of Revenue to the committee at periodic question and answer sessions. 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 a specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.
Q&A with the Pennsylvania Department of Revenue
When does a complete or partial liquidation of a business still constitute non-business income under the Laurel Pipe Line, Ross-Araco and Canteen decisions?
Nonbusiness income is limited to that income that is not apportionable under the United States Constitution. If the income is apportionable to any other jurisdiction, it is apportionable business income for Pennsylvania purposes.