Q&A with the Pennsylvania Department of Revenue

In 2016, a question was posed asking DOR’s position regarding the PIT treatment of an IRC sec. 351 transaction with boot. The Department never provided an answer. What is the DOR’s position on this issue?

Jan 22, 2018
For PIT purposes, all the gain would be recognized as taxable if boot received pursuant to 72 P.S. §7303(a)(3)(iv). 

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Annual Meetings
Disclaimer

These documents provide a summary of the answers provided by the Department of Revenue to the PICPA Committee on State Taxation at its annual question and answer session. 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 their specific fact situation may request a written letter ruling under 61 Pa. Code Section 3.3.