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
What are the PA PIT tax consequences of a conversion of a PA S Corporation to a limited partnership, and would the transaction be subject to tax?
Historically the department treated this transaction as the termination of one entity and the creation of a new entity. This was the general rule prior to 2015 since the Commonwealth did not have a conversion statute. There is no definitive policy at this time and the department is considering the effect of the 2015 statute.