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2025 Income Tax Letter Rulings

Ruling Date Subject Synopsis
IT 25-0001-GIL 03/10/2025 Alternative Apportionment Petition to include property and payroll apportionment factors in sales factor calculation cannot be granted merely because the alternative method reaches a different apportionment percentage than the required statutory formula.
IT 25-0002-GIL
03/17/2025 Alternative Apportionment Apportionment of separate businesses under 86 Ill. Adm. Code Section 100.3010(b) does not require petition for alternative apportionment. (This is a GIL.)
IT-25-0003-GIL 03/26/2025 Alternative Apportionment Apportionment of separate businesses under 86 Ill. Adm. Code Section 100.3010(b) does not require petition for alternative apportionment. (This is a GIL.)
IT-25-0004-GIL 05/06/2025 Income Tax - Subtractions Subtraction modification may be claimed in the same tax year a taxpayer receives the Employee Retention Credit and reports an overstated wage expense amount as gross income on its federal return for the disallowed wage deduction. (This is a GIL.)
IT-25-0005-GIL 07/28/2025 Partnerships The gain from the sale of Illinois real property as the sole partnership asset is allocated to this State under Section 303 or Section 304 of the Illinois Income Tax Act. (This is a GIL.)
IT-25-0006-GIL 07/29/2025 Subtractions Retirement income, including amounts passed through from an estate or trust, is eligible for a subtraction modification under IITA Section 203(a)(2)(F).
IT-25-0007-GIL 08/15/2025 Nexus Nexus issues are not generally suitable for resolution by letter ruling. (This is a GIL.)
IT-25-0008-GIL 08/15/2025 Miscellaneous This letter responds to an annual survey. (This is a GIL.)
IT 25-0009-GIL 09/11/2025 Residency Changing the situs of a trust may result, depending on other relevant factors, in a change of residence for tax purposes. (This is a GIL).

Private Letter Rulings

Ruling Date Subject Synopsis
IT-25-0001-PLR 08/04/2025 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.)