These documents reflect private letter rulings issued by the Department of Revenue in response to specific taxpayer requests. The letters have been redacted to protect the identities of the taxpayers who made the requests.
To find out more about technical rulings, see Technical (private letter) rulings.
| Name | Description | Released | Format |
|---|---|---|---|
| BIRT NOL Ruling PDF | No Discretion to Vary from Statutory NOLs | September 16, 2024 | |
| Ruling on advisor incentives and fees PDF | Private ruling on whether business advisor fees and incentives are subject to the Business Income and Receipt Tax and the Net Profits Tax. | March 20, 2024 | |
| Realty Transfer Tax ruling on statutory conversions PDF | Realty Transfer Tax is not imposed on statutory conversion. | August 23, 2023 | |
| Multi-transaction Realty Transfer Tax ruling PDF | The City will accept a one-time Realty Transfer Tax payment in a multi-phase low-income transaction. | January 27, 2023 | |
| Goodwill sales and intangible assets ruling PDF | Applicability of the Business Income and Receipts Tax (BIRT) to sales attributed to goodwill and intangible assets. | April 13, 2023 | |
| Realty Transfer Tax ruling on mergers PDF | Real Transfer Tax is not due in the event of a merger. | August 23, 2023 | |
| Realty Transfer Tax ruling PDF | An LLC engaged in a business other than real estate is not a real estate company is subject to the City of Philadelphia's Realty Transfer Tax | April 24, 2021 | |
| Realty Transfer Tax ruling on parking subsidiaries PDF | Whether the City of Philadelphia would consider a parking subsidiary as a real estate company for Realty Transfer Tax. | April 30, 2021 | |
| Ruling on the apportionment of BIRT’s net income and gross receipts PDF | Applicability of the Business Income and Receipts Tax to sale proceeds attributed to goodwill. | April 29, 2021 | |
| Non-resident Wage Tax ruling – Employer standard requirement PDF | Whether wages paid to non-resident employees are subject to the Wage Tax in various situations. | October 29, 2021 | |
| Non-resident Wage Tax ruling PDF | Applicability of the Wage Tax to wages paid to non-resident employees. | October 29, 2021 | |
| Philadelphia residential property subject to SIT PDF | Whether purchase of a residential property in Philadelphia will subject an individual to the City’s School Income Tax (SIT). | March 13, 20218 | |
| Sweetened beverage subject to PBT PDF | Addresses whether dealer-manufactured sweetened beverages are subject to the Philadelphia Beverage Tax. | June 12, 2017 | |
| Sugar beverage ruling PDF | Whether frozen concentrates, water enhancers, and powered mixes are subject to the City of Philadelphia’s Sugar-Sweetened Beverage Tax (SBT). | May 3, 2017 | |
| UBTI subject to BIRT and CAL doc | Whether Federal Unrelated Business Taxable Income (UBTI) is subject the City of Philadelphia Business Income and Receipts Tax and Commercial Activity License. | June 8, 2012 | |
| Board Committeemembers doc | Are volunteer board members engaged in business for the purposes of the Business Privilege Tax, and Net Profits Tax? | December 22, 2011 | |
| New Markets Tax Credit and Business Privilege Tax doc | Addresses whether a person or organization who has received a New Markets Tax Credit is still subject to the Business Privilege Tax. | October 26, 2010 | |
| Supplemental unemployment benefits ruling PDF | Applicability of the Wage Tax to supplemental unemployment benefits. | February 06, 2009 |