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 2023-02 | Allocation and Apportionment of Contract Manufacturing Service Fees |
| CPLR 2023-01 | Controlled Foreign Corporation with Activity in North Carolina due to a Single Member Limited Liability Company |
| Redetermination Letter Dated 1/06/2023 | Combined Reporting |
| CPLR 2022-01 | Mill Rehabilitation Tax Credit |
| CPLR 2021-01 | Proper Sourcing of Receipts |
| Redetermination Letter Dated 12/31/2020 | Combined Reporting |
| 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 |