Robert L. McNeil, Jr. Trust ex rel. McNeil v. Commonwealth
Commonwealth Court of Pennsylvania
1Opinion of the Court
OPINION BY
Judge COHN JUBELIRER.
In 2007, the Department of Revenue (Department) assessed Pennsylvania In*188come Tax (PIT) and interest on all of the income of two inter vivos trusts, which are located in, administered in, and governed by the laws of Delaware and which had no Pennsylvania income or assets in 2007. The Department imposed the PIT because the trusts’ settlor, Robert L. McNeil, Jr. (Settlor), resided in Pennsylvania when he established the trusts in 1959 and the trusts’ discretionary beneficiaries are Pennsylvania residents. On appeal, the Robert L. McNeil, Jr. Trust for Nancy M.…
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