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 |
|---|---|---|---|
| Realty Transfer Tax ruling on mergers PDF | Addresses whether Real Transfer Tax is due in the event of a merger. | July 17, 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 (BIRT) and the Net Profits Tax (NPT). | July 17, 2024 | |
| Realty Transfer Tax ruling on parking subsidiaries PDF | Addresses whether the City of Philadelphia would consider a parking subsidiary as a real estate company | July 17, 2024 | |
| Non-resident Wage Tax ruling – Employer standard requirement PDF | Redacted private ruling regarding whether wages paid to non-resident employees are subject to the City's employer standard requirements. | July 17, 2024 | |
| Realty Transfer Tax ruling on statutory conversions PDF | Redacted private ruling on whether Realty Transfer Tax is imposed on statutory conversions. | July 17, 2024 | |
| Multi-transaction Realty Transfer Tax ruling PDF | Addresses whether the City will accept a one-time Realty Transfer Tax payment in a multi-phase transaction. | July 17, 2024 | |
| Ruling on the imposition of the Realty Transfer Tax PDF | Redacted private letter ruling on imposition of Realty Transfer Tax. | July 17, 2024 | |
| Realty Transfer Tax ruling PDF | Addresses whether an LLC that isn't a real estate company is subject to the City of Philadelphia's Realty Transfer Tax | July 17, 2024 | |
| 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 |