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Legal Research

In this area, you will find topics regarding Decisions, Rulings, Procedures, and Private Taxpayer Rulings from the Arizona Department of Revenue:

 

  • Arizona Administrative Code - the official rules of the state of Arizona are published. The Code is the official compilation of rules that govern state agencies, boards, and commissions.
  • Arizona Revised Statutes - the statutory laws for the state of Arizona.

 

Find topics regarding Decisions, Rulings, Procedures, and Private Taxpayer Rulings from the Arizona Department of Revenue:

  • Decisions from the Arizona Department of Revenue Hearing Office and the Director’s Office.
  • Private Taxpayer Rulings/Taxpayer Information Rulings - The department's interpretation of the law or rules only as they apply to the taxpayer and facts contained in the request.
  • Tax Procedure provides procedural guidance to the general public to assist in the implementation of tax laws, administrative rules, and tax rulings.
  • Tax Rulings - Written statement of the Arizona Department of Revenue's position interpreting the Arizona tax law and applying the law to a specific set of facts or a particular tax situation.
  • Draft Documents - In an ongoing effort to interact with and inform the public regarding issues relating to taxation, we would appreciate your written comments on these drafts.  We will review all comments that are received by the noted due dates and make any appropriate revisions before issuing the final documents.  For your convenience, you may submit your comments using the contact information provided on the cover page for each draft document.
  • Conformity to IRC - Each year the Arizona legislature considers whether to amend Arizona Revised Statutes § 43-105 to conform to changes made to the Internal Revenue Code during the prior year. 

 

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Document Type Category Document ID Description Tags Decision Date
Decisions Corporate Tax 201800182-C

Combined reporting of overall net income by parent company and its unitary affiliates was necessary where parent designed and developed programs for implementation by its affiliates and directed the affiliates' day-to-day operations.

Hearing 05/05/2020
Decisions Corporate Tax 200800188-C

Sourcing of slot machine owner’s receipts for sales factor purposes.  Whether placing machines in casinos was rental of personal property.

Hearing 02/11/2020
Decisions Corporate Tax 201200235-C

Gross receipts from Taxpayer’s sale of its assets should be excluded from the sales factor.

Hearing 05/31/2013
Decisions Corporate Tax 201100309-C

Taxpayer did not use its investment account in its regular trade or business so its investment income was not business income. Reimbursement of shared business expenses from a co-tenant was business income.

Hearing 07/30/2012
Decisions Corporate Tax 200900134-C

To claim an enterprise zone credit the taxpayer must be the employer.

Director 05/24/2011
Decisions Corporate Tax 200800192-C

Calculation of the enterprise zone credit amount

Hearing 10/16/2009
Decisions Corporate Tax 200800128-C

Gain from a §338(h)(10) sale of a subsidiary should be treated as business income

Hearing 07/10/2009
Decisions Corporate Tax 200700189‑C

Taxpayer not allowed research and development credit, under A.R.S. 43-1168, where the Taxpayer relies on unsubstantiated estimates of research expenditures from an acquired company in years preceding the acquisition of such company to calculate the credit.

Director 02/09/2009
Decisions Corporate Tax 200700189-C

Tax credit study was not based on sufficient evidence to prove entitlement to an increased research and development credit.

Director 02/06/2009
Decisions Corporate Tax 200600091-C

Gain from the sale of stock in a foreign subsidiary owned by a holding company was apportionable business income.

Director 09/08/2008
Decisions Corporate Tax 200600091-C

Gain from the sale of stock in a foreign subsidiary owned by a holding company was apportionable business income.

Director 09/08/2008
Decisions Corporate Tax 200700083-C

Whether Arizona has sufficient nexus to tax income from an out-of-state franchisor that receives license and royalty fees from Arizona franchisees.

Hearing 03/27/2008
Decisions Corporate Tax 200600161-C

Net operating loss carryforward and continuity of business enterprise; municipal bond interest.

Director 10/29/2007
Decisions Corporate Tax 200600082-C

Are gains arising from certain transactions business or nonbusiness income?

Hearing 06/15/2007
Decisions Corporate Tax 200600161-C

In calculating Arizona net operating loss carryforward in a merger; Is the exclusion of in-state municipal bonds, unconstitutional?

Hearing 06/07/2007
Decisions Corporate Tax 200600091-C

Do gains arising from sales of common stock of a majority -owned overseas subsidiary constitute busness income apportionable to Arizona?

Director 05/14/2007
Decisions Corporate Tax 200600105-C

Effect of prior closing agreement concerning use of the completed contract method of accounting and an apportionment method for completed contracts.

Hearing 03/07/2007
Decisions Corporate Tax 200500075-C

Does the construction of storm water retention areas and sewer systems qualify for credit as pollution control equipment.

Director 02/12/2007
Decisions Corporate Tax 200500147-C

Does the construction of storm water retention areas and sewer systems qualify for credit as pollution control equipment.

Director 01/26/2007
Decisions Corporate Tax 200600088-C

Whether a merger termination fee is business or non-business income; A.R.S. 42-2076

Hearing 10/10/2006
Decisions Corporate Tax 200600035-C

REIT dividend deduction not allowed where the corporate REIT and beneficiary are part of the same unitary group

Hearing 09/15/2006
Decisions Corporate Tax 200400017-C

Arizona consolidated group was required to include in the numerator of the Arizona sales factor a portion of the sales made by a partnership, in which some members of the group had an interest, to another member of the group doing business in Arizona.

Director 12/09/2004
Decisions Individual Income Tax 202100028-I

Automatic stay after taxpayer's bankruptcy petition did not apply.  The issuance of assessments is not an action to collect a debt against either the debtor taxpayer or a bankruptcy estate, but rather an act to determine liability.

Hearing 01/27/2022
Decisions Individual Income Tax 202100029-I

Taxes in assessments issued in 2019 were not subject to a bankruptcy discharge order where the taxpayer had filed the bankruptcy petition in 2016. The issuance of assessments is not an action to collect a debt, but rather an act to determine liability.  Whether some or part of the tax assessed is affected by a bankruptcy filing is a different question from whether the issuance of an assessment is valid.

Hearing 01/27/2022
Decisions Individual Income Tax 202100037-I

A.R.S. § 43-1071(F) did not create new and otherwise unavailable credit for taxes paid to California where group return filed in California had forfeited California credit for taxes paid in Arizona.

Hearing 12/14/2021
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Arizona
Department of Revenue
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