Written Determinations Corporate Tax

Pursuant to N.C. Gen. Stat. § 105-264, “[i]t is the duty of the Secretary to interpret all laws administered by the Secretary. An interpretation by the Secretary is prima facie correct.” Pursuant to N.C. Gen. Stat. § 105-264.2, “[a] written determination applies the tax law to a specific set of existing facts furnished by a particular taxpayer. A written determination is applicable only to the individual taxpayer addressed and as such has no precedential value except to the taxpayer to whom the determination is issued. A written determination includes a private letter ruling.

Private Letter Rulings Issued (includes Redeterminations)

PLR # Subject
CPLR 2020-01 Proper Sourcing of Receipts
CPLR 2019-01 Franchise Tax Treatment of Property Owned by Non-Corporate Entities
Redetermination Letter Dated 3-18-2019 Combined Reporting
Redetermination Letter Dated 3-28-2018 Combined Reporting
Redetermination Letter Dated 10-9-2017 Combined Reporting
CPLR 2017-01 Credit for Railroad Intermodal Facilities
Redetermination Letter Dated 8-11-2017 Combined Reporting
Redetermination Letter Dated 12-7-2016 Combined Reporting
CPLR 2016-02 Credit for Investing in Renewable Energy Property
CPLR 2016-01 Association Exempt from Gross Premiums Tax
CPLR 2015-12 Investing in Renewable Energy Property
CPLR 2015-11 Investing in Renewable Energy Property
CPLR 2015-10 Investing in Renewable Energy Property
CPLR 2015-09 Historic Rehabilitation Credit
CPLR 2015-08 Investing in Renewable Energy Property
CPLR 2015-07 Investing in Renewable Energy Property
CPLR 2015-06 Mill Rehabilitation Credit
CPLR 2015-05 Renewable Energy Credit
CPLR 2015-04 Renewable Energy Credit
CPLR 2015-03 Mill Rehabilitation Credit
CPLR 2015-02B Business and Energy Credits – Solar Photovoltaic Facility
CPLR 2015-02 Business and Energy Credits – Solar Photovoltaic Facility
CPLR 2015-01 Investing in Renewable Energy Property - Cost
Redetermination Letter Dated 09-04-2015 Combined Reporting
CPLR 2014-12 Renewable Energy Credit - Installations
CPLR 2014-11 Renewable Energy Credit – Placed in Service
CPLR 2014-10 Article 3C Incentives for Recycling Facilities
CPLR 2014-09 Renewable Energy Credit
CPLR 2014-08 Renewable Energy Credit
CPLR 2014-07 Renewable Energy Credit
CPLR 2014-06 Renewable Energy Credit – Credit Utilization
CPLR 2014-05 Renewable Energy Credit
CPLR 2014-04 Renewable Energy Credit – Credit Utilization
CPLR 2014-03 Combined Return
CPLR 2014-02 Renewable Energy Credit - Basis
CPLR 2014-01 Combined Return
CPLR 2013-05B Renewable Energy Credit
CPLR 2013-04B Renewable Energy Credit
Redetermination Letter Dated 12-19-2014 Combined Reporting
Redetermination Letter Dated 02-07-2014 Combined Reporting
CPLR 2013-16 Investing in Renewable Energy Property
CPLR 2013-15 Treatment of Promissory Note Interest
CPLR 2013-14 Constructing Renewable Fuel Facility
CPLR 2013-13 Investing in Renewable Energy Property
CPLR 2013-12 Apportionment – Is Company Excluded Corporation
CPLR 2013-11 Investing in Renewable Energy Property
CPLR 2013-10-2 Investing in Renewable Energy Property
CPLR 2013-10 Investing in Renewable Energy Property
CPLR 2013-09R Investing in Renewable Energy Property
CPLR 2013-08 Investing in Renewable Energy Property
CPLR 2013-07 Investing in Renewable Energy Property
CPLR 2013-06 Investing in Renewable Energy Property
CPLR 2013-05A Renewable Energy Credit – Multiple Installations
CPLR 2013-04A Renewable Energy Credit – Multiple Installations, One Project Location
CPLR 2013-03 Renewable Energy Credit – Credit Ceiling
CPLR 2013-02 Renewable Energy Credit – Capital Lease
CPLR 2013-01 Wind Energy – Renewable Energy Credit
Redetermination Letter Dated 04-30-2013 Combined Reporting
CPLR 2012-12 Sourcing Income
CPLR 2012-11 Renewable Energy Property
CPLR 2012-10 Renewable Energy Credit
CPLR 2012-09 Combined Corporate Income Tax Return
CPLR 2012-08 Impact of Bond Financing on Energy Credit
CPLR 2012-07 Renewable Energy – Separate Installations
CPLR 2012-06 Renewable Energy – Installation of Renewable Energy Property
CPLR 2012-05 Who Can Claim Credit When Renewable Energy Property is Leased
CPLR 2012-04 Credit for Qualifying Expenses of a Production Company
CPLR 2012-03 Credit for Creating Jobs in Short Tax Years
CPLR 2012-02 Apportionment – Income from Services Provided
CPLR 2012-01 Eligibility – Article 3A/Article 3J Credits
Redetermination Letter Dated 10-09-2012 Combined Reporting
CPLR 2011-09 Mill Rehabilitation Tax Credit
CPLR 2011-08 Treatment of NEL in Merger
CPLR 2011-07 Apportionment – Is Company Excluded Corporation
CPLR 2011-06 Renewable Energy – Solar Power Generating and Solar Thermal Equipment
CPLR 2011-05 Eligibility – Investing in Renewable Energy Property
CPLR 2011-04 Eligibility for Renewable Energy Tax Credit
CPLR 2011-03 Eligibility for Qualifying Expenses of a Production Company
CPLR 2011-02 Treatment of NEL When Two Companies Merge
CPLR 2011-01 Apportionment – Excluded Corporation
Redetermination Letter Dated 09-26-2011 Combined Reporting
CPLR 2010-10 Availability of Article 3J Tax Credits
CPLR 2010-09 Investing in Renewable Energy Property – Leased Property
CPLR 2010-08R Investing in Renewable Energy Property
CPLR 2010-07 Service Income from Sources outside North Carolina
CPLR 2010-06 Investing in Renewable Energy Property – Leased Property
CPLR 2010-05 Investing in Renewable Energy Property
CPLR 2010-04 Eligibility for Business Incentive Credits – Article 3J
CPLR 2010-03 Solar Power Generating Equipment – Renewable Energy
CPLR 2010-02 Apportionment – Property Factor
CPLR 2010-01 Investing in Renewable Energy Property