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
For Capital Stock and Franchise Tax purposes, what is considered sufficient detail and support when the adjustment is NOT book income?
Each case is controlled by specific facts and circumstances. An adjustment to book income is reviewed and analyzed along with supporting documentation to determine its impact on book income for CS/FF purposes. Given that the taxpayer has the burden of proof, they should provide all relevant documentation so that the Department can fully understand the nature of the transaction.