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
Scenario: Corporation recently learned that it was subject to a CNI tax in 2013 and 2014
ABC Corp., a Delaware corp. based outside PA, filed a RCT-101 in 2013 and 2014, but only completed the FF Tax section. The corporation claimed P.L. 86-272 protection for CNI Tax purposes. Recently, the corporation learned that it was subject to the CNI Tax in 2013 and 2014.
Should ABC Corp. report the CNI Tax on an original or amended RCT-101? How should ABC Corp. complete the FF Tax section on the tax report?
As stated in prior years the RCT-101 is three tax reports on one document. In this case the RCT-101 will be filed as the original report for corporate next income tax. The CSFT of the RCT-101 should report the components of the tax which is used to calculate the current tax liability; the reports should contain a statement explaining the reason for the filing of the report. This will need to emailed to the following resource account: RA-RVCORPSPCHANDLE@pa.gov
Note: This does not open additional appeal rights for CSFT.