What is a Binding Letter Ruling?
A letter ruling is the Department of Revenue's response to a taxpayer's request for specific information about the tax treatment of a particular facet of the taxpayers' business or personal situation. The letter ruling is confidential, specific to the facts of the situation, and is binding on the Department of Revenue with respect to the taxpayer requesting the ruling for three years from the issue date of the letter. Letter rulings are not binding on the Department of Revenue with respect to any other taxpayers.
Because the issues in one taxpayer's letter ruling may provide guidance to another taxpayer in determining the taxability of a similar situation, the Department of Revenue publishes redacted versions of all letter rulings (with all identifying information removed). You may search by topic or, if you know the assigned number of the letter ruling, by the letter ruling number.
If you would like to receive a binding determination concerning the specific facts of your situation, submit a Request for Letter Ruling (Form 5859). Any taxpayer may request a binding letter ruling. You must follow specific rules when making your request. Regulation 12 CSR 10-1.020 codifies these rules.