61 Pa. Code § 91.202
Example 1:
A and B are equal partners in their partnership. Over a period of 2 years, the partnership adds 18 new equal partners. As A and B own only 10% of the total ownership interest at the end of the 2-year period, the addition of the new members has the effect of transferring 90% of the total ownership interest in the partnership. The partnership, therefore, became an acquired company upon the admittance of the 20th partner.
Example 2:
C and D are equal partners in their partnership. C transfers her 50% partnership interest to E. One year later, E transfers the 50% partnership interest to F. The partnership does not become acquired as a result of these changes. As D still retains his 50% interest, 50% of the total ownership interest remains the same. The series of transactions relating to C's interest has the effect only of transferring 50% of the total ownership interest.
Example: C and D each own all of the stock of a corporation in equal shares. C and D transfer their stock to E, C's son, over a 3-year period. As C and E are members of the same family, the transfer between C and E is not a change in ownership interest. Thus, the stock transfers have the effect of transferring only 50% of the total ownership interest in the corporation and the corporation is not acquired.
61 Pa. Code § 91.202
The provisions of this §91.202 issued under section 1107-C of the Tax Reform Code of 1971 (72 P. S. § 8107-C).
This section cited in 61 Pa. Code § 91.113 (relating to imposition of tax on declarations of acquisition); and 61 Pa. Code § 91.193 (relating to excluded transactions).