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
In determining a corporation’s sales factor, is it acceptable to use PJM’s ISO load factor as a means of sourcing receipts to Pa. from spot sales of electricity on the PJM network? The BF&R granted PSEG Energy Resources & Trade LLC relief on the issue.
The decision of the Board of Finance and Revenue is on appeal at Commonwealth Court.