Section 212 of the Insurance Department Act of 1921 (the Act), Act of May 17, 1921, P.L. 789, as amended, 40 P.S. 50. The retaliatory tax due, if any, "is calculated by comparing the burdens that another state imposes on Pennsylvania insurance companies doing business in that state, to burdens that Pennsylvania imposes on foreign insurance companies doing business in Pennsylvania, and a retaliatory tax is designed to equalize those burdens." Guardian Life Ins. Co. of Am. v. Commonwealth, 148 Pa. Commw. 430, 611 A.2d 797, 798 (Pa. Cmwlth. 1992). In Guardian Life, we summarized the purpose of Section 212 of the Act as follows: The retaliatory tax, although commonly referred to as a "tax," is not technically a tax, but is more properly a business license fee or charge, imposed to regulate insurance companies. the purpose of Section 212 and of similar laws enacted in almost every state, is to encourage equal treatment of domestic and foreign insurance companies, and to break down interstate barriers. Section 212 "is certainly not a revenue raising measure. In fact, its success might be said to depend on how little is collected under its terms rather than how much." Id. at 799.