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Services
2021 Income Tax Letter Rulings
General Information Letters
| Ruling | Date | Subject | Synopsis |
| IT 21-0001-GIL |
04/14/2021 |
Residency |
Income earned in a foreign country not taxable if taxpayer established a new domicile. (This is a GIL.) |
| IT 21-0002-GIL |
05/11/2021 |
Alternative Apportionment |
Alternative apportionment not appropriate where including all of the gross receipts attributable to the sale of goodwill in the sales factor denominator does not reflect the market for the taxpayer's goods, services or other ordinary sources of business income because such sourcing differs from the sales factor computed without regard to that sale. (This is a GIL.) |
| IT 21-0003-GIL |
06/04/2021 | Non-Resident Withholding |
Withholding of Illinois income tax not required for Compensation paid to a nonresident for services not performed in Illinois. |
| IT 21-0004-GIL |
08/31/2021 |
Apportionment-Virtual Currency |
For purposes of Section 304 of the IITA and accompanying regulations, bitcoin is considered "intangible personal property." Bitcoin is not considered a "patent, copyright, trademark, or similar item of intangible property" to which 35 ILCS 5/304(a)(3)(B-1) and (B-2) and accompanying regulations would apply. (This is a GIL.) |
| IT 21-0005-GIL |
08/30/2021 | Credits | Historic Preservation Tax Credit Historic Preservation Credit may be Allocated to Partners Pursuant to Agreement of Partners. (This is a GIL.) |
| IT 21-0006-GIL |
08/31/2021 |
Nexus | Department does not issue rulings on nexus, however the taxpayer may not be required to file an Illinois Income tax return if they do not meet the requirements of Section 502(a) of the IITA. (This is a GIL.) |
| IT 21-0007-GIL |
10/14/2021 |
Residency | Whether an irrevocable trust continues to be subject to Illinois income tax after the beneficiaries and trust administration are relocated out of state.(This is a GIL) |
| IT 21-0008-GIL |
10/01/2021 |
Miscellaneous |
This letter responds to an annual survey. (This is a GIL.) |
| IT 21-0009-GIL |
11/23/2021 |
Exemptions – Standard Exemption |
If a taxpayer's total base income is greater than their Illinois income, the taxpayer must prorate their standard exemption to account for income from sources outside of Illinois. (This is a GIL) |
| IT 21-0010-GIL |
11/23/2021 |
Subtractions |
Annuity and benefit funds created under the Illinois Pension Code are eligible for subtraction modification under Section 203(a)(2)(F) because the funds constitute "retirement or disability plan(s) for employees of any governmental agency or unit." |
| IT 21-0011-GIL |
11/23/2021 | Pensions-Foreign Pensions |
Some German pensions governed by U.S tax treaty with Germany may qualify for subtraction modification found in IITA Section 203(a)(2)(L). (This is a GIL.) |
| IT 21-0012-GIL |
11/23/2021 |
Non-Resident Withholding | Withholding of Illinois income tax required for Compensation paid to a nonresident for services performed in Illinois. |
| IT 21-0013-GIL |
12/08/2021 |
Alternative Apportionment |
Alternative apportionment not appropriate where royalties earned from licensing the use of intangible personal property did not compromise more than 50% of taxpayer's total gross receipts included in gross income and are excluded from sales factor pursuant to IITA Section 304(a)(3)(B-2). (This is a GIL.) |
Private Letter Rulings
| Ruling | Date | Subject | Synopsis |