Taxpayer favorably settles corporate net income tax dispute with Pennsylvania Department of Revenue

Client(s) Taxpayer

Jones Day represented a manufacturer in administrative appeals before the Pennsylvania Board of Finance and Revenue involving corporate net income tax assessments for several tax years. The dispute concerned whether the royalty add-back exception under 72 Pa. Stat. § 7401(3)(t) applied to intercompany intellectual property licensing transactions with a Delaware affiliate. Jones Day negotiated favorable settlements with the Department of Revenue’s Office of Chief Counsel.