Letter Rulings
A private taxpayer ruling or a taxpayer information ruling is the department's interpretation of the law or rules only as they apply to the taxpayer making, and the particular facts contained in, the request.
The Department of Revenue (Department) is authorized[1] to issue private taxpayer rulings (PTRs) or taxpayer information rulings (TIRs) to provide Arizona taxpayers with guidance relating to their specific tax situation. A PTR may be requested when the taxpayer’s identity is provided. A TIR may be requested without providing a taxpayer’s identity. When the taxpayer’s identity is known, a PTR may be issued and is binding on the Department. Whereas a TIR is only binding if the taxpayer’s identity is provided to the Department. The identity of the taxpayer does not have to be provided on the initial request for a TIR.
A PTR or TIR is a written statement issued to a taxpayer or the taxpayer representative by the Department’s Tax Policy Section. A PTR or TIR interprets and applies Arizona tax laws to a particular set of facts. The Department will issue a PTR or TIR in response to a written inquiry by a taxpayer, potential taxpayer, or an authorized representative of a taxpayer or potential taxpayer. A taxpayer, potential taxpayer, or an authorized representative may request an informal guidance letter in lieu of a PTR or TIR.
The Department will accept a request for a PTR or TIR in a hard copy (i.e., paper) format. A taxpayer may also send the request through email to [email protected]. The request should be as complete as possible and all relating documentation should be submitted at the time of the request.
Once the Department has received a taxpayer’s request, it will be reviewed and the taxpayer will be contacted within five business days if additional information is needed. The taxpayer should return any requests for additional information from the Department within a minimum of five business days. A letter ruling will be issued within 45 business days after all information (including responses to questions) is received. At any time during the ruling process, the taxpayer may request a conference with the Department by sending an email to [email protected]. The Department may also request a conference with the taxpayer to clarify any outstanding questions or issues.
If a taxpayer or taxpayer representative does not receive a ruling within the timeframe specified above, please reach out to Department employee working on the ruling with a copy to Lisa Querard at [email protected] for more information.
For more information on PTR and TIR requests, please review General Tax Procedure (GTP) 08-1 and General Tax Ruling (GTR) 08-1 on our website.
1 Authorization for letter rulings can be found in the Arizona Revised Statutes (A.R.S.) 42-2101.
Document Type | Category | Document ID | Description | Tags | Decision Date |
---|---|---|---|---|---|
Letter Rulings | Corporate Tax | LR15-007 | Taxation of AHCCCS contractors that pay premium tax under Title 36 | General | 07/14/2015 |
Letter Rulings | Corporate Tax | LR13-004 | Business/Nonbusiness Determination Of Expected Judgment Proceeds | General | 04/29/2013 |
Letter Rulings | Corporate Tax | LR11-001 | Taxation of Insurance Company and its Single Member Limited Liability Company | General | 02/08/2011 |
Letter Rulings | Corporate Tax | LR10-010 | Taxation of insurance companies | General | 11/08/2010 |
Letter Rulings | Corporate Tax | LR10-008 | Elimination from the Sales Factor of Intercompany Amounts that Flow Through from a Partnership | General | 03/24/2010 |
Letter Rulings | Corporate Tax | LR08-10 | Taxation of Insurance Companies | General | 10/27/2008 |
Letter Rulings | Corporate Tax | LR04-002 | Transfer of Credits Upon Merger | General | 03/04/2004 |
Letter Rulings | Corporate Tax | LR02-011 | Pollution Control Credit | General | 05/23/2002 |
Letter Rulings | Corporate Tax | LR99-002 | Taxation of Insurance Companies | General | 02/18/1999 |
Letter Rulings | Estate Tax | LR 03-010 | Federal Credit for Taxes paid on Prior Transfers | General | 09/25/2003 |
Letter Rulings | Estate Tax | LR 99-004 | Federal Credit for Taxes paid on Prior Transfers | General | 03/15/1999 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 21-003 | Rental of digital information and data. | Personal Property Rental | 05/27/2021 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 21-002 | Sourcing the city privilege tax on long-term motor vehicles for an out-of-state lessor. |
Personal Property Rental, Sourcing | 04/19/2021 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 21-002 | Sourcing the city privilege tax on long-term motor vehicles for an out-of-state lessor. |
Personal Property Rental, Sourcing | 04/19/2021 |
Letter Rulings | Transaction Privilege and Use Taxes | LR21-001 | Retail Classification, baked goods delivered | Retail | 03/22/2021 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-016 | Implications of A.R.S. § 42-5075(Q) when a property developer is required by the sales contract to complete unfinished modifications/improvements to the land. | Prime Contracting | 12/10/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-012 | Retail - Sales of Insertable Cardiac Monitors | Retail | 09/18/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-011 | Membership fees as a nontaxable separate line of business |
Membership, Nonprofit, Retail | 09/01/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 22-003 | Long term ground lease of improved real property. |
Commercial Lease, Speculative Builder | 09/01/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-011 | Membership fees as a nontaxable separate line of business |
Membership, Nonprofit, Retail | 09/01/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-011 | Membership fees as a nontaxable separate line of business |
Membership, Nonprofit, Retail | 09/01/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 22-003 | Long term ground lease of improved real property. |
Commercial Lease, Speculative Builder | 09/01/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-008 | Tower Crane, Mobile Crane and Construction Hoist Rentals |
Personal Property Rental, Prime Contracting, Publication | 07/16/2020 |
Letter Rulings | Transaction Privilege and Use Taxes | LR 20-008 | Tower Crane, Mobile Crane and Construction Hoist Rentals |
Personal Property Rental, Prime Contracting, Publication | 07/16/2020 |