Corporate Tax Q&A with Pennsylvania Department of Revenue

Q&A with Pennsylvania Department of Revenue

Corporate Tax

Has the Department of Revenue further considered any income tax implications of the Wayfair decision? If so, can it provide guidance?
When can we expect market-based sourcing regulations?
Is Form REV-986 required for taxpayers claiming PL 86-272 protection?
What is the Board of Appeals' policy of refusing to grant relief in cases that involve the application of the net loss fixed dollar limitation for tax years after 2006? The R.B. Alden and General Motors cases involve pre-2007 tax years.
What is the status of the JP Morgan Securities, Inc. and New Cingular Wireless PCS cases, and what is the income producing activity/cost of performance appeals that the Department may litigate?
How does the Department of Revenue determine on audit whether a corporate taxpayer's method of sourcing service receipts is reasonable?
Scenario: Under IRC § 860E a holder of a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) is required, at a minimum, to pay tax on its excess inclusion income (EII).
When does the Department of Revenue anticipate issuing draft market-based sourcing regulations for comments by interested parties, or for public comment?
Does the Department of Revenue have the authority to assert economic nexus for CNI Tax under the current statute without a law change, and if so, does it intend to assert economic nexus?
For taxpayers with both inter-company interest and third-party interest, what is the Department of Revenue's position on the ordering of interest limitations under IRC §163(j)?
How does the Department of Revenue plan to apply the new IRC §163(j) interest limitations to members of a federal consolidated group who file separately for Pennsylvania corporate net income tax?
How should a corporate taxpayer apply the IPA/COP method to source goodwill from the sale of a business?
How should a corporate taxpayer apply the IPA/COP method to source receipts/gain from the sale of a patent, trademark or similar intangible for CNIT purposes?
Should a corporate taxpayer apply the income producing activity/cost of performance (IPA/COP) method to source royalties or other receipts from the licensing of marketing and non-marketing intangibles for CNIT purposes?
May a corporate taxpayer rely upon the MTC’s Section 17 regulation for purposes of sourcing receipts from services until the DOR issues market-based sourcing regulations for CNIT purposes?
How should a taxpayer handle a notice of assessment for a year in which the appeal deadline has passed regarding the former Capital Stock/Foreign Franchise Tax (CSFT)?
Scenario: The REIT may have PA modifications to federal taxable income
Scenario: Applying the add-back provision
As a follow-up to Corporation Tax Information Notice 2016-1, does the Department of Revenue plan to provide additional guidance related to part III?
When a personal income tax return is audited, (unreimbursed business expenses), does the Department respond to the taxpayer/practitioner indicating that the information has been received?

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