Skip to main content

2022 Income Tax Letter Rulings

Ruling	Date	Subject	Synopsis
IT 22-0001-GIL	02/23/2022	Subtractions	Corporations disallowed a federal wage deduction for the Employee Retention Credit are eligible for a subtraction modification as provided in IITA Section 203(b)(2)(I)(ii). (This is a GIL.)
IT-22-0002-GIL	01/11/2022	Alternative Apportionment	Alternative apportionment not appropriate when gross receipts arising from an incidental or occasional sale of assets used in the regular course of trade or business are excluded from the sales factor pursuant to 86 Ill.Adm. Code 100.3380(c)(2). (This is a GIL.)
IT-22-0003-GIL	02/25/2022	Miscellaneous	This letter responds to an annual survey(This is a GIL.)
IT-22-0004-GIL	03/24/2022	Trusts	Illinois will follow the federal income tax treatment afforded to a trust for State income tax purposes. (This is a GIL.)
IT-22-0005-GIL	04/12/2022	Unspecified Income-Annuities	Annuity proceeds paid to Illinois estate and distributed to nonresident beneficiaries are unspecified income not allocated to Illinois pursuant to IITA Section 301(c)(2)(A) (This is a GIL.)
IT-22-0006-GIL	04/15/2022	Allocation - Guaranteed Payments from Partnership to Resident	Resident partners include guaranteed payments in Illinois base income. (This is a GIL.)
IT-22-0007-GIL	04/15/2022	Annualization - Installment Computation	Standard exemption is disallowed in the computation of annualization installment if the adjusted gross income for that period exceeds IITA Section 204(g) thresholds. (This is a GIL.)
IT-22-0008-GIL	05/10/2022	Partnerships	Nonresident partner that sells its share of non-unitary partnership allocates nonbusiness capital gain from the sale under Section 303 of the Illinois Income Tax Act. (This is a GIL.)
IT-22-0009-GIL	06/14/2022	Nexus/Corporate Filing Requirements	Nexus issues are not generally suitable for resolution by letter ruling. (This is a GIL.)
IT-22-0010-GIL	07/15/2022	Miscellaneous	This letter responds to an annual survey. (This is a GIL.)
IT-22-0011-GIL	09/13/2022	Alternative Apportionment	Alternative apportionment not appropriate when gross receipts arising from an incidental or occasional sale of assets used in the regular course of trade or business generate a gain in goodwill are excluded from the sales factor pursuant to 86 Ill. Admin. Code Section 100.3380(c)(2). (This is a GIL.)
IT-22-0012-GIL	12/06/2022	Miscellaneous	An Illinois resident trust with Illinois based assets must file an Illinois income tax return. (This is a GIL.)

Private Letter Rulings

Ruling	Date	Subject	Synopsis
IT-22-0001-PLR	03/15/2022	Apportionment - Insurance Companies	Taxpayer's request to change method of sourcing reinsurance premiums under IITA Section 304(b)(2) is granted. (This is a PLR.)
IT-22-0002-PLR	04/12/2022	Addition Modifications - Other Rulings	Taxpayer who claimed bonus depreciation addition and subtraction modifications under IITA Sections 203(b)(2)(E-10) and (T) must add back the aggregate amount of subtraction modifications claimed on the property in the taxable year of an IRC Section 368(a)(1)(D) corporate reorganization. (This is a PLR.)
IT-22-0003-PLR	08/02/2022	Alternative 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.)