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Written Determinations

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 may include any one or more of the following:

  • An alternative apportionment ruling.
  • A private letter ruling.
  • A redetermination private letter ruling.

The text of a written determination must be published on the Department's website within 90 days of the date the determination is provided to the taxpayer and redacted in the manner required by the statute.

Written Determination Policy

To access Written Determinations issued on or after January 1, 2010 and required to be published by the Department, select the tax type below, as applicable: