If a non-C-Corp hasn't had other registrations in PA in the past (sales tax, employer withholding, etc.), is it required to go through the bulk sale reporting process when it sells its assets? For example, a real estate LLC selling its real estate.

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

If a non-C-Corp hasn't had other registrations in PA in the past (sales tax, employer withholding, etc.), is it required to go through the bulk sale reporting process when it sells its assets? For example, a real estate LLC selling its real estate.

Nov 15, 2019
Yes. A bulk sale clearance certificate would still be required in the example to permit a review and clearance, at the very least, of the LLC's PA 20S/65 requirements.
 

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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.