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
Would the economic nexus be sufficient to subject a corporation to the CNIT and/or CSFT?
During a recent meeting with the Philadelphia Bar Association SALT Committee, the Acting Chief Counsel indicated that the economic nexus would be sufficient to subject a corporation to the CNIT and/or CSFT. Please confirm whether her comment reflects a change in longstanding Department of Revenue policy. Please provide examples where economic nexus will create nexus.
The Department interprets the statutes of the Commonwealth to allow taxation to the limits of the United States Constitution. There is no change in the policy of the Department.