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Redacted technical rulings

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
Ruling on the apportionment of BIRT’s net income and gross receipts PDF Redacted private letter ruling dealing with the applicability of the net income and gross receipts portions of the Business Income and Receipts Tax (BIRT) to a sale attributed to goodwill. June 2, 2023
Sweetened beverage subject to PBT PDF Addresses whether dealer-manufactured sweetened beverages are still subject to the Philadelphia Beverage Tax (PBT). June 2, 2023
Goodwill sales and intangible assets ruling PDF Redacted private letter ruling dealing with the applicability of the Business Income and Receipts Tax (BIRT) to sales attributed to goodwill and intangible assets. June 2, 2023
Philadelphia residential property subject to SIT PDF Ruling on whether a residential property in Philadelphia is subject to the City’s School Income Tax (SIT). June 2, 2023
Non-resident Wage Tax ruling PDF Addresses the applicability of the Wage Tax to wages paid to non-resident employees. June 2, 2023
Sugar beverage ruling PDF Ruling on whether frozen concentrates, water enhancers, and powered mixes are subject to the City of Philadelphia’s Sugar-Sweetened Beverage Tax (SBT). June 2, 2023
Supplemental unemployment benefits ruling PDF Redacted private letter ruling dealing with the applicability of the Wage Tax to supplemental unemployment benefits. February 06, 2009
Board Committeemembers doc Are volunteer board members engaged in business for the purposes of the Business Privilege Tax (BPT), and Net Profits Tax (NPT)? January 25, 2017
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. January 25, 2017
UBTI subject to BIRT and CAL doc Ruling on whether the Federal Unrelated Business Taxable Income (UBTI) is subject the City of Philadelphia Business Income and Receipts Tax and Commercial Activity License. January 25, 2017

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