Private Letter Rulings

What Are Private Letter Rulings?

A Private Letter Ruling is an informational statement of the Commission's interpretation of statute or administrative rules and their application to a particular set of facts or circumstances. A Private Letter Ruling typically addresses unusual or complex questions pertaining to a particular taxpayer. Routine tax questions are generally addressed by the correspondence group of the Taxpayer Services Division.

The Commission will not issue a Private Letter Ruling to a taxpayer who has the issue pending before the Tax Commission on appeal. The weight given a Private Letter Ruling in a subsequent appeal by the same taxpayer depends upon the degree to which the underlying facts were adequately described to allow thorough consideration of the issues and interests involved.

To protect the privacy of the taxpayer, confidential information is removed from the private letter rulings prior to publication.

Searchable Database of Private Letter Rulings

Due to the number of rulings available, we can't offer a full listing. Instead, we've provided this database that includes rulings dating back to 1989. Hint: put your search phrase in "quotes" to search for an exact phrase.

Recent Private Letter Rulings

Click on headings to sort.

COM_FABRIK_ORDERPLR Number COM_FABRIK_ORDERResponse Date COM_FABRIK_ORDERSubject Matter
12-010 02/08/2013 Sales Taxation Implications of Sales of Gift Codes
12-009 02/08/2013 Sales Nexus and Corporate Franchise Tax Nexus Analysis for Out-of-State Companies Attending Festival and Tradeshow in Utah
10-012 12/06/2012 Sales Tax Treatment of Web-Based Database Services
12-002 12/07/2012 Utah Sales Tax Treatment of Sales of Access to Online News Service
12-005 11/28/2012 Laboratory Testing Services Performed in Utah for Out-of-State Customers
12-008 11/26/2012 Validity of a Paper-Filed Utah Tax Return Signed Through An Alternative Signature Method
12-006 09/04/2012 Private Letter Ruling Request on the Application of the Utah Special Fuel Tax
11-007 08/16/2012 Utah Sales Tax Treatment of Repair Services on Turbine Generators Located in Utah and Used to Generate Electricity for Sale
12-004 05/31/2012 For Sales Tax Purposes, the Applicability of the Farming Operations Exemption Found in § 59-12-104(18) to Pipe Purchased by a Mutual Nonprofit Irrigation Company
11-005 03/21/2012 Private Letter Ruling Request–Multi-Channel Audio and Video Service Tax Treatment of Certain Separately Stated Cable Charges
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