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2025 Sales Tax Letter Rulings

Ruling Date Subject Synopsis
ST 25-0001-GIL
 01/08/2025 Sale for Resale A Certificate of Resale must contain the items of information set out in 86 Ill. Adm. Code 130.1405. (This is a GIL).
ST-25-0002-GIL
 01/17/2025 Service Occupation Tax Effective January 1, 2025, persons engaged in the business of making sales of service are subject to State and local service occupation tax on all tangible personal property transferred by lease as an incident of a sale of service. See 35 ILCS 115/3 as amended by Article 75 of Public Act 103-592.
ST-25-0003-GIL
 12/13/2024 Food This letter discusses the State tax rate applicable to sales of food. See 86 Ill. Adm. Code 130.310. (This is a GIL.)
ST-25-0004-GIL 01/27/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL.)
ST-25-0005-GIL
 02/03/2025 Marketplace Facilitator An internet auction listing service meeting the requirements of a marketplace facilitator, including one of the tax remittance thresholds, is considered a marketplace facilitator. See 86 Ill. Adm. Code 130.1915(c); 86 Ill. Adm. Code 131.105; 86 Ill. Adm. Code 131.135. The participation of a marketplace facilitator in the collection and payment process under 86 Ill. Adm. Code 131.130(a)(1)(B) is not limited to instances where the purchaser directly pays the marketplace facilitator, and the marketplace facilitator directly remits the payment to the marketplace seller. See 86 Ill. Adm. Code 131.130(a)(1)(B). (This is a GIL.)
ST-25-0006-GIL 02/04/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL.) 
ST-25-0007-GIL 02/21/2025 Manufactured Homes Mobile homes and manufactured homes in mobile home parks must be assessed and taxed as chattel. See 35 ILCS 517/5. When a mobile home park owner purchases a manufactured home from the manufacturer to be installed in the mobile home park and sold to a purchaser, the purchase from the manufacturer is a tax-free purchase for resale. The first sale by the mobile home park owner of the manufactured home located in the mobile home park to a purchaser is reported and paid on Form ST-556, Sales Tax Transaction Return. Each subsequent sale of the manufactured home by the mobile home park owner to another purchaser must also be reported and paid on Form ST-556. NOTE: This letter supersedes ST 24-0047-GIL. (This is a GIL.)
ST-25-0008-GIL 03/04/2025 Drugs and Medical Appliances A medical appliance is an item that directly substitutes for a malfunctioning part of the human body. Products that qualify as medical appliances are taxed at a lower State tax rate of 1% plus any applicable local taxes. 86 Ill. Adm. Code 130.311. (This is a GIL).
ST 25-0009-GIL 03/05/2025 Medical Appliance A medical appliance is an item that directly substitutes for a malfunctioning part of the human body. Products that qualify as medical appliances are taxed at a lower State tax rate of 1% plus any applicable local taxes. 35 ILCS 120/2-10; 35 ILCS 120/14; 86 Ill. Adm. Code 130.311. (This is a GIL).
ST 25-0010-GIL 03/11/2025 Telecommunications Excise Tax Responds to inquiry about various telecommunications-related taxes. See 35 ILCS 630/3 and 4; 35 ILCS 635/15. (This is a GIL).
ST 25-0011-GIL 03/12/2025 Leasing If the true object of the transaction is the rental of space or providing an amusement, no tax is incurred on the charges for the space or the amusement. If no separate charge is made under the agreement for the incidental amount of tangible personal property provided, the renter is considered the user of the tangible personal property and incurs use tax on its cost price of the tangible personal property transferred incidentally to the purchase of space or an amusement and used in the course of using that space or partaking in that amusement. If a separate charge is made for any tangible personal property transferred by rental or lease incidentally to the rental of space or providing an amusement, the renter incurs retailers’ occupation tax on the rental or lease price of the tangible personal property. See generally 86 Ill. Adm. Code 130.2145(e). (This is a GIL.)
ST 25-0012-GIL 03/14/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL).
ST 25-0013-GIL 03/13/2025 Medical Appliance A medical appliance is an item that directly substitutes for a malfunctioning part of the human body. Products that qualify as medical appliances are taxed at a lower State tax rate of 1% plus any applicable local taxes. 35 ILCS 120/2-10; 35 ILCS 120/14; 86 Ill. Adm. Code 130.311. (This is a GIL). 
ST 25-0014-GIL 03/17/2025 Food This letter discusses the State tax rate applicable to the sales of food. 35 ILCS 120/2- 10; 86 Ill. Adm. Code 130.310. (This is a GIL.)
ST 25-0015-GIL 03/18/2025 Remote Retailers This letter provides information regarding Retailers’ Occupation Tax remittance obligation of remote retailers. See 86 Ill. Adm. Code 131. (This is a GIL.)
ST-25-0016-GIL 03/18/2025 Trade-Ins No trade-in credit may be taken for that portion of the purchase price of a new automobile representing a settlement which the purchaser has obtained from an automobile manufacturer pursuant to the New Vehicle Buyer Protection Act [815 ILCS 380]. See 86 Ill. Adm. Code 130.425(h). (This is a GIL).
ST-25-0017-GIL 03/18/2025 Graphic Arts Special order printed material that would not be considered stock or standard items and would not be sold to someone other than the purchaser for substantially the same price would not be subject to the Retailers’ Occupation Tax when sold, but would be subject to the Service Occupation Tax. See 86 Ill. Adm. Code 130.2000. (This is a GIL).
ST 25-0018-GIL 03/24/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and localretailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL). 
ST 25-0019-GIL 03/24/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and localretailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL). 
ST 25-0020-GIL 03/25/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL).
ST 25-0021-GIL 04/07/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a GIL.)
ST 25-0022-GIL 04/07/2025 GROSS RECEIPTS Federal importation taxes are not deductible, in computing Retailers’ Occupation Tax liability, from the gross receipts of persons who sell such tangible personal property at retail. See 86 Ill. Adm. Code 130.445.

 

Private Letter Rulings

Ruling Date Subject Synopsis
ST-25-0001-PLR 02/04/2025 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. (This is a PLR.)