Illinois Department of Revenue
 
 
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2006 Income Tax Letter Rulings

 
 

General Information Letters

Ruling
Date
Subject Synopsis
IT 06-0037-GIL
12/26/2006
Alternative Apportionment General Information Letter: Petition for alternative apportionment contained insufficient information to allow a determination.
IT 06-0036-GIL
12/12/2006
Credits – Film Credit General Information Letter: The amount of film production services credit allowable is determined by the Department of Commerce and Economic Opportunity.
IT 06-0035-GIL
11/22/2006
Credits – Foreign Tax General Information Letter: Explanation of computation of "double taxed income" for California.
IT 06-0034-GIL
11/15/2006
Credits – Foreign Tax General Information Letter Prior to 2006, no credit is allowed for taxes paid to another state on compensation "paid in this State."
IT 06-0033-GIL
11/02/2006
Residency/Nonresidency General Information Letter: A trust is an Illinois resident if its grantor was an Illinois resident at the time the trust became irrevocable.
IT 06-0032-GIL
10/26/2006
Military General Information Letter: Petition for alternative apportionment contained insufficient information to allow a determination.
IT 06-0031-GIL
10/12/2006
Public Law 86-272/Nexus General Information Letter: The amount of film production services credit allowable is determined by the Department of Commerce and Economic Opportunity.
IT 06-0030-GIL
10/11/2006
Refunds – Statutes of Limitations General Information Letter: Explanation of computation of "double taxed income" for California.
IT 06-0029-GIL
10/04/2006
Composite Returns General Information Letter: A taxpayer may claim a credit on his or her individual income tax return for taxes paid on a composite return only if prior permission has been received from the Department.
IT 06-0028-GIL
09/12/2006
Refunds – Statutes of Limitations General Information Letter: The special statutory provisions for investment partnerships were not in effect for 2003.
IT 06-0027-GIL
09/11/2006
Public Law 86-272/Nexus General Information Letter: Nexus determinations generally cannot be made in the ruling process.
IT 06-0026-GIL
09/11/2006
Exempt Organizations – Investment Partnerships General Information Letter: Investments in real estate are not qualifying investments for purposes of determining whether a partnership is an investment partnership.
IT 06-0025-GIL
09/07/2006
Bingo, Pull Tabs and Charitable Games General Information Letter: Casino Night described in the ruling is not a charitable game.
IT 06-0024-GIL
08/14/2006
Subtractions – Other Rulings General Information Letter: Illinois allows subtractions for interest earned on Home Ownership Made Easy accounts and for education loan repayments of certain primary care physicians. Response to State of Wisconsin questionnaire on basic principles of Illinois income taxation in IT 06-0014 GIL corrected.
IT 06-0023-GIL
07/31/2006
Partnerships General Information Letter: Special allocation rules for income received from an investment partnership do not apply to tax years ending prior to July 30, 2004.
IT 06-0022-GIL
07/31/2006
Partnerships General Information Letter: Special allocation rules for income received from an investment partnership do not apply to tax years ending prior to July 30, 2004.
IT 06-0021-GIL
07/25/2006
Composite Return General Information Letter: Nonresident individual is granted permission to claim on his individual return a credit for tax paid on his behalf on a composite return.
IT 06-0020-GIL
07/19/2006
Credits – Foreign Tax General Information Letter: Illinois allows a credit for taxes paid by a resident to other states on income taxed by Illinois, including (beginning in 2006) wages paid in this State.
IT 06-0019-GIL
07/10/2006
Returns General Information Letter: Material Advisor ordered by IRS to turn over some investor information and to retain remainder pending IRS request need not turn over retained information to the Department until requested by the IRS or the Department.
IT 06-0018-GIL
07/06/2006
Apportionment - Sales Factor General Information Letter: Activities performed by third parties are not income producing activities of the taxpayer for sales factor purposes.
IT 06-0017-GIL
06/29/2006
Alternative Apportionment General Information Letter: Alternative apportionment petition could not be granted because it was not timely filed for old taxable years and, for current year, contained no information that would support a conclusion that the statutory apportionment formula did not fairly represent the business activities of the taxpayer in Illinois or that the alternative would better represent the business activities of the taxpayer in Illinois.
IT 06-0016-GIL
06/19/2006
Withholding - Other Rulings General Information Letter: No withholding of Illinois tax is required from compensation paid to Illinois residents for employment in Missouri when Missouri taxes are withheld and the compensation is not "paid in this State" under IITA Section 304(a)(2)(B).
IT 06-0015-GIL
06/13/2006
Subtraction Modifications - Other Rulings General Information Letter: No subtraction modification is allowed for losses passed through from a partnership and disallowed in computing federal adjusted gross income of the partner in order to reflect a pro-forma recomputation of the federal loss limitation to take into account Illinois addition modifications.
IT 06-0014-GIL
06/09/2006
Miscellaneous General Information Letter: Response to State of Wisconsin questionnaire on basic principles of Illinois income taxation.
IT 06-0013-GIL
06/07/2006
Residency/Nonresidency General Information Letter: Explanation of principles for determining residency.
IT 06-0012-GIL
05/31/2006
Withholding - Other Rulings General Information Letter: Wages paid to a nonresident who is based in another state and performs no services in Illinois are not subject to Illinois income tax or to withholding.
IT 06-0011-GIL
05/19/2006
Subtraction Modifications - Qualified Pension Plans General Information Letter: Pensions of retired government employees, including other states' governments, qualify for subtraction.
IT 06-0010-GIL
05/15/2006
Subtraction Modifications - Other Rulings General Information Letter: No subtraction modification is allowed unless expressly provided in IITA Section 203 or if it would allow a double deduction.
IT 06-0009-GIL
05/15/2006
Subtraction Modifications - Other Rulings General Information Letter: No subtraction modification is allowed unless expressly provided in IITA Section 203 or if it would allow a double deduction.
IT 06-0008-GIL
05/15/2006
Subtraction Modifications - Other Rulings
General Information Letter: No subtraction modification is allowed unless expressly provided in IITA Section 203 or if it would allow a double deduction.
IT 06-0007-GIL
05/15/2006
Subtraction Modifications - Other Rulings General Information Letter: No subtraction modification is allowed unless expressly provided in IITA Section 203 or if it would allow a double deduction.
IT 06-0006-GIL
05/02/2006
Apportionment - Sales Factor General Information Letter: Brokerage business conducted in Missouri with only connection to Illinois by telephone would have no Illinois sales factor.
IT 06-0005-GIL
04/06/2006
Compensation General Information Letter: Gain of a nonresident on stock options treated as compensation for income tax purposes is taxed by Illinois only if it is "paid in this State" under IITA Section 304(a)(2)(B).
IT 06-0004-GIL
03/01/2006
Miscellaneous General Information Letter: The Department of Revenue cannot provide guidance regarding whether "local law" prohibits the claiming of a person as a dependent for federal income tax purposes.
IT 06-0003-GIL
01/24/2006
Credits - Other Rulings General Information Letter: An institution that provides only preschool and kindergarten-level education is not a school qualifying for the education expense credit.
IT 06-0002-GIL
01/03/2006
Withholding - Other Rulings General Information Letter: Explanation of the quarter-monthly deposit requirement for withholding.
IT 06-0001-GIL
01/03/2006
Subtraction Modifications - Pensions General Information Letter: Illinois does not tax pensions of nonresident individuals.

Private Letter Rulings

Ruling Date Subject Synopsis
IT 06-0002-PLR 03/09/2006 Amnesty Private Letter Ruling: Taxpayer whose liability for an amnesty year resulted from a disposition after the amnesty period of stock received in a reorganization in the amnesty year did not qualify for amnesty because the liability was created by the disposition. Accordingly, any interest and penalties attributable to the liability are not doubled.
IT 06-0001-PLR
01/17/2006
Credits – Other Rulings Private Letter Ruling: A partner is entitled to the portion of the film production services credit shown on the final certificate issued by DCEO that is allocated to it by the partnership agreement.

 
 
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