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2019 Income Tax Letter Rulings

General Information Letters

Ruling	Date	Subject	Synopsis
IT 19-0001-GIL	01/14/2019	Credit - Hospital Credit	Credit Equals Lesser of Real Property Taxes Paid or Cost of Free or Discounted Services.
IT 19-0002-GIL	01/30/2019	Partnerships - Pass-Through Withholding	Pass-through entity may not claim refund or credit for overpayment of withholding. (This is a GIL.)
IT 19-0003-GIL	02/11/2019	Subtraction Modification (Retirement Income)	Dividends from Taxable Brokerage Account may not be Subtracted. (This is a GIL.)
IT 19-0004-GIL	04/02/2019	Base Income	Group-term life insurance coverage over $50,000 is considered part of AGI for purposes of calculating Illinois base income. (This is a GIL.)
IT 19-0005-GIL	04/15/2019	Residency/Non-Residency	Individuals domiciled in Illinois who are on short-term assignments overseas generally remain liable for Illinois income tax.
IT 19-0006-GIL	05/01/2019	Credits-Other	Various issues related to the credits for costs of remediating properties in a River Edge Redevelopment Zone addressed. (This is a GIL.)
IT 19-0007-GIL	05/10/2019	Refunds-Credit of Overpayment to Liabilities	Regulation 100.9400 requires Department to credit overpayments to liability for tax imposed under the IITA. (This is a GIL.)
IT 19-0008-GIL	05/10/2019	Withholding-Other Rulings	A general explanation is provided of the principles for determining when compensation paid to an employee providing services within and without Illinois is subject to withholding. (This is a GIL.)
IT 19-0009-GIL	05/23/2019	Education Expense Credit	Explanation of how education expense credit applies to various items used for home schooling purposes. (This is a GIL.)
IT 19-0010-GIL	05/23/2019	Credit - Foreign Tax	Gambling winnings are sourced to the state of residence of the individual winner, so are not included in the computation of the cap on the credit allowed under IITA Section 601 (b)(3). (This is a GIL.)
IT 19-0011-GIL	05/30/2019	Base Income - Medical Cannabis Expenses	Absent express subtraction modification, medical cannabis dispensing organization operating costs that would be considered trafficking in marijuana under federal law cannot be deducted from AGI and must be included in the calculation of base income for purposes of calculating income tax due under the IITA. (This is a GIL.)
IT 19-0012-GIL	06/24/2019	Allocation	Deferred compensation is "paid in this State" to the extent paid for services for which the ordinary compensation was "paid in this State." (This is a GIL.)
IT 19-0013-GIL	07/09/2019	Education Expense Credit	Explanation of how education expense credit applies to various items used for home schooling purposes. (This is a GIL.)
IT 19-0014-GIL	07/09/2019	Base Income - Unrelated Business Taxable Income	IRAs with unrelated business taxable income are subject to the requirements of Section 205 of the Illinois Income Tax Act. (This is a GIL.)
IT 19-0015-GIL	07/12/2019	Returns - Requirements to File	Executor is not required to file a return on behalf of deceased if deceased individual was not required by IITA to file a return. (This is a GIL.)
IT 19-0016-GIL	08/07/2019	Base Income PFIC Income	Shareholder of PFIC Includes in Base Income PFIC Income Included in Federal AGI.
IT 19-0017-GIL	12/10/2019	Nexus	Whether taxpayer has nexus with Illinois is extremely fact-specific. Department does not issue rulings regarding nexus with the State. (This is a GIL.)
IT 19-0018-GIL	10/25/2019	Foreign Income Tax Credit	Compensation paid in Illinois under IITA Section 304(a)(2)(B) does not qualify for the credit for taxes paid to other states. (This is a GIL.)
IT 19-0019-GIL	I0/24/2019	Nonresident Trusts	Trust whose only connection to Illinois is an investment advisor should be considered a nonresident trust. (This is a GIL.)

Private Letter Rulings

Ruling	Date	Subject	Synopsis
IT 19-0001-PLR	08/14/2019	Sales Factor	Gross Receipts from Investment Advisory Services are Sourced to Billing Address of Customer.
IT 19-0002-PLR	08/14/2019	Sales Factor	Gross Receipts from Investment Advisory Services are Sourced to Billing Address of Customer.
IT 19-0003-PLR	08/12/2019	Apportionment - Sales Factor	Private Letter Ruling: Receipts from deemed sale of assets comprising entire business are excluded from the sales factor as being from an occasional sale.
IT 19-0004-PLR	12/17/2019	(Alternative Apportionment) Alternative Method of Apportionment	Taxpayer is granted permission to apportion interest income and income received from the sale of the right to receive future contingent payments by using the same apportionment factor for the year in which Taxpayer sold rights and property to a third party. (This is a PLR.)