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Pennsylvania Institute Of Certified Public Accountants

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Q&A with Pennsylvania Department of Revenue

Corporate Tax

Does the DOR treat the sale of electricity as the sale of tangible personal property, intangible personal property, or as a service for CNI Tax and CS/FF Tax purposes?
Does the DOR treat the sale of natural gas as the sale of tangible personal property, intangible personal property, or a service for CNI Tax and CS/FF Tax apportionment purposes?
For CNI Tax and CS/FF Tax purposes, are gross proceeds or net gains from the sale of derivatives, e.g., futures, options and swaps, includable in a corporation’s sales factor (assuming that the derivatives are not securities)?
For CNI Tax and CS/FF Tax apportionment purposes, is the sale or licensing of canned software delivered electronically treated as the sale of tangible personal property or the sale/licensing of intangible property?
Which appeal rights does a corporate taxpayer have if the DOR refuses to accept all the changes reported on an RCT-128C?
Scenario: For federal income tax purposes, a corporation prepares its federal Form 1120, Schedule UTP, and Uncertain Tax Position Statement on a consolidated basis.
Scenario: A corporation reports and remits a self-assessed CNIT.
Scenario: A corporation does business in PA and files an RCT-101 as part of a consolidated group.
Does the DOR intend to assert IRC § 7701(o) (Clarification of Economic Substance Doctrine) as a basis for challenging certain intercompany transactions for CNIT purposes?
Under what circumstances, if any, would PA permit or require an adjustment to an NOL carryover from a closed year being applied in an open year?
Would the delivery of goods to customers in PA by a corporation using its own trucks and drivers create nexus for CNIT purposes?
Would the delivery of goods to customers in PA by a corporation using its own trucks and drivers create nexus for foreign franchise tax purposes?
Scenario: using apportionment factors to determine CNIT and foreign franchise tax liabilities
Under what circumstances does the DOR believe market sourcing is an appropriate policy?
What is the DOR's position regarding IRC Sec. 108?
What are the rules and instructions for paying corporate balance due payments using etides and EFTPS?
When did the PA DOR Corporate Tax Bureau start requesting additional information using faxes? Why not by U.S. mail?
Why is the procedure of the PA DOR for follow up on an information request (in this case the R&D credit application) if information is not received from the taxpayer as a result of a fax request?
Would a distribution from an LLC to a corporate member be included in the corporate member’s net income if it constituted a “return of capital"?
Is there interest for late payment of tax after timely filing a CNIT extension?

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