PA PIT law does not specifically incorporate or follow IRC § 355 like some other IRC provisions. However, PA PIT does contain provisions that exempt certain types of corporate reorganizations from tax which would otherwise normally create taxable gain. Those provisions can be found at 72 P.S. § 7303(a)(3)(iv). If the spinoff meets the statutory criteria of a reorganization, then any gain would not be taxable. A blanket statement whether all IRC § 355 spinoffs are tax-free for PA PIT purposes cannot be issued without having all the possible scenarios in which IRC Section 355 can be applied. If specific facts are provided for a taxpayer, the department would be happy to provide an opinion on those facts as they relate to that specific situation.