Pennsylvania Commonwealth Court Sustains Revenue’s Source Analysis

Joe Bright and Heidi Schwartz co-authored an article published in Bloomberg Tax analyzing the Pennsylvania Commonwealth Court’s recent decision in Synthes USA HQ, Inc. v. Pennsylvania. A divided en banc panel held that the Department of Revenue correctly sourced sales of services made in the 2011 tax year to Pennsylvania for purposes of the sales factor for corporate net income tax (CNIT), because the recipients of the services received the benefit of the services in Pennsylvania. Joe and Heidi conclude that if this decision stands, it would it would validate an incorrect interpretation of the statute at issue, impede the attorney general, and undermine the effect of legislative changes to Pennsylvania statutes. Exceptions to the court’s opinion have been filed by the attorney general.


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Joseph C. Bright


(215) 665-2053

Heidi R. Schwartz


(215) 665-2799

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