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Redacted Private Letters

Redacted Private Letter Rulings (Redacted PLR) are a type of declaratory ruling that is written to provide guidance to a specific taxpayer at the taxpayer’s request. Although Private Letter Rulings (PLR) formally apply to only the taxpayers to whom the letters are addressed, the department recognizes that the information in such rulings might be useful as a guide to how the department might apply the law to other situations of facts identical or essentially similar to those described in the PLR. The Private Letter Ruling is “redacted” – all taxpayer identifying information has been removed and any other measures needed to protect taxpayer confidentiality.

Number Title Date Issued
10-027 Concerning the Eligibility of Liquefied Natural Gas for the Sales Tax Exemption Provided by R.S. 47:305(D)(1)(g) for Natural Gas (10/22/2010) 10/22/2010
10-023 Concerning Whether a Physician Qualifies for the Small Town Doctor Credit (10/22/2010) 10/22/2010
10-018 Concerning Whether a Corporation Organized Exclusively to Provide Benefits as a Prescription Drug Plan Under the Federal Government’s Medicare Part D Program Is Subject to Corporation Franchise Tax (10/14/2010) 10/14/2010
10-016 Clarification Concerning the Solar Energy Systems Tax Credit 09/14/2010
09-019 Concerning Whether the State Sales or Use Tax is Due on Purchases of Ingestible Medical Diagnostic Capsules 09/14/2009
09-018 Qualification for the Solar Energy Systems Tax Credit 10/06/2009
09-010 Musical and Theatrical Production Tax Credit 02/13/2009
08-023 Credit for the Rehabilitation of Historic Structures in Downtown Development Districts 11/05/2008
08-022 Motion Picture Infrastructure Credit 10/28/2008
08-017 Historic Rehabilitation Credit 10/06/2008
08-010 Private Letter Ruling No. 08-010 – Concerning the Sales and Use Tax Payable on the Equipment That Is Furnished to Customers by a Wireless Internet Service Provider (8/15/2008) 08/15/2008
08-009 Allocation of Partnership Income Between States 08/04/2008
08-007 Whether or Not a Member of an Affiliated Group will be Subject to Louisiana Corporation Income or Franchise Taxes 03/27/2008
07-017 Credit for the Rehabilitation of Historic Structures in Downtown Development Districts 11/08/2007
07-015 Concerning the applicability of sales or use tax to replacement vehicles under manufacturer’s warranty or Louisiana’s Lemon law 12/04/2007
07-001 Motion Picture Investor Tax Credit as Currently Amended 02/05/2007
06-010 Concerning the Sales Taxability of Sales and Installations of Durable Medical Imaging Equipment In Hospitals 07/24/2006
06-005 Concerning the Sales Taxability of a Lease Termination Payment Required Under a Lease Agreement After the Destruction of the Leased Asset by Hurricane 04/26/2006
06-002 Concerning Whether a Sales and Use Tax Exemption Applies to Indirect or Overhead Costs on Projects Performed By a Contractor for the Federal Government 11/21/2006
06-001 Historic Rehabilitation Tax Credit Earned by a Downtown Development District 01/18/2006
05-015 Franchise Tax Liability of Limited Liability Companies 02/09/2006
05-014 Louisiana Net Operating Loss Subsequent to Reorganization 02/09/2006
05-003 Discussing the Sales Taxability of Electronic Discovery Services Provided to Litigation Teams 03/24/2005
04-006 Discussing Whether Various Charges Within the Purchase Price of a Communications System Form Part of the Use Taxable “Cost Price” of the System, as Provided by La. Rev. Stat. Ann. § 47:301(3)(a) 09/07/2004
04-004 Location of the Commercial Domicile of a Corporation 09/13/2004
04-003 Deduction of Transportation Costs from Value of Oil and/or Condensate 09/02/2004
04-001 Income and Franchise Tax Exemptions for Health Maintenance Organizations 06/30/2004
03-022 The Sales Taxability of Certain Sales for Employee or Customer Incentive Programs 01/21/2004
03-014 Transferability and Application of Motion Picture Investor Tax Credit 12/17/2003
03-013 Exemption for Banks Organized Under Laws of Other States 12/12/2003
03-012 Small Town Doctor’s Credit 11/07/2003
03-011 Conditions that Determine for Sales Tax Purposes When Carpet Installation is a Sale of Tangible Personal Property With An Obligation to Install or An Immovable Property Contract 10/16/2003
03-009 Concerning Whether the Parts and Accessories for Hospital-Owned Medical Linear Accelerators Are Eligible for the Sales Tax Exemption Provided by R.S. 47:305(D)(1)(s) for Personally Used Medical Devices 09/09/2003
03-008 Sales Taxability of Purchases by Individual Public Schools 07/03/2003
03-007 Sales Taxability of Certain Charges by a Country Club To Its Members 04/29/2003
03-006 Availability of the Motion Picture Investor and Employment Credits 04/17/2003
03-005 The Status of Already-Installed Durable Medical Equipment as Movable or Immovable Property for Sales and Use Tax Purposes 03/17/2003
03-004 Taxability of Sales of Digital Subscriber Line (DSL) Service to Consumers For Their Use Solely in Accessing the Internet 04/04/2003
03-003 Sales Tax Collection Exemption at Events Held in Publicly Owned Facilities, as Provided by Louisiana Revised Statute 39:468. 03/17/2003
03-002 Sales Taxability of the Payments that an Owner of Tangible Personal Property Receives From a Lessor Who Has Secured Lease/Rental Customers for the Owner’s Property 02/25/2003
02-015 Private Letter Ruling Concerning Availability of the Motion Picture Investor Tax Credit 12/13/2002
02-013 Private Letter Ruling Concerning Availability of Motion Picture Investor Tax Credit 11/27/2002
02-003 Eligibility of Blind Vendors for Sales Tax Exemption 08/29/2002
02-002 Sales Taxability of Charges for High-Speed Satellite Downloading, Internet Access, and Telecommunication Services 04/01/2002
01-011 Sales Taxability of the Construction and Lease of a Cogeneration Power Plant 01/22/2001
01-009 Private Letter Ruling on income taxation of a Qualified Subchapter S Subsidiary 03/08/2002
01-008 Sales Taxability of Cylinder Testing and Related Services 01/22/2001
01-007 Private Letter Ruling on Sales Tax Treatment of Leased Equipment that has been rendered an Immovable Component of a Building 10/10/2001
01-006 Carpet Cleaning and Installation, Building Contents Cleaning, Furniture Cleaning and Storage, Furnishing of Cleaning Equipment 12/12/2001
01-004 Private Letter Ruling on Taxation of Severance Pay for Personal Income Tax 10/03/2001
01-003 Due Date for the Remittance by the Seller of Sales Taxes on Sales of Season Tickets of a Professional Athletic Team When Payments are Made in Installments 12/12/2001
01-001 Department Issues Private Letter Ruling Confirming Absence of "Throwback" Rules in Income and Franchise Taxes 07/25/2001