Official State of Rhode Island website

State of Rhode Island Division of Taxation Department of Revenue

Declaratory Rulings

A Declaratory Order is an explanation of a statute and/or regulation and its applicability to a requester’s particular facts. 

A Declaratory Order is issued at the request of a taxpayer and is limited to the facts set forth therein. The Order has precedential value and may be generally relied on by all persons with respect to substantially similar transactions.

To submit any inquiries related to Declaratory Orders, including to request a Declaratory Order, to withdraw a request for issuance of a Declaratory Order, or to provide additional documents/information related to the request for an Order, direct your inquiry by email to: Tax.Legal@tax.ri.gov.

Please note that in accordance with 280-RICR-20-00-5, all requests for Declaratory Orders must include the name, address, and registration/identification number of the taxpayer requesting the Order and a carefully detailed statement of all relevant facts relating to the transaction, among other things. Please refer to 280-RICR-20-00-5 for detailed information.

For alternate inquiry submission options, please contact the Division’s Legal Section at: Tax.Legal@tax.ri.gov.

The below rulings were issued based on the facts as set forth in the declaratory ruling requests and statutory and regulatory provisions in effect at the time of the ruling. Please refer to the cited statutes and regulations within each ruling to ensure the guidance is current as the applicable provisions of law may have been amended.

 
Document Document Description View
R2024-01 Request for Ruling Regarding the Taxability of Charges for Entertainment Services and Related Activities View
R2023-02 Request for Ruling Regarding the Application of Sales Tax View
R2023-01 Request for Ruling Regarding the Application of Sales and Use Tax View
R2021-02 Request for Ruling Regarding the Application of an Exemption from Sales and Use Tax View
R2021-01 Request for Ruling Regarding the Application of Sales Factor Sourcing Rules to Certain Business Corporation Tax Transactions View
R2020-03 Request for Ruling Regarding the Taxability of Vendor-Hosted Prewritten Computer Software View
R2020-02 Request for Ruling Regarding the Estate Tax Treatment of Proceeds from Certain Settlement Claims View
R2020-01 Request for Ruling Regarding the Taxability of the Taxpayer’s Cleanrooms Under the Sales and Use Tax View
R2019-03 Request for Ruling Regarding the Taxability of a Paint Stewardship Assessment View
R2019-02 Request for Ruling Regarding the Applicability of R.I. Gen. Laws § 44-18-30(57) to Certain Components Used in Renewable Energy Products View
R2019-01 Request for Ruling Regarding the Application of the Federal Capital Construction Fund ("CCF") Program to Rhode Island Personal Income Taxes View
R2018-01 Request for Ruling Regarding the Obligations of the Parties in Connection with the Design, Construction, and Installation of a Solar Photovoltaic System View
R2017-05 Request for Ruling Regarding the Taxability of Supply Item Purchases View
R2017-04 Request for Ruling Regarding the Applicability of R.I. Gen. Laws § 44-18-30(48) to the Sale and Storage, Use, or Other Consumption of a Boat View
R2017-03 Request for Ruling Regarding the Taxability of the Use of a Mobile Point of Sale Device in the Restaurant Industry View
R2017-02 Request for Ruling Regarding the Taxability of Cloud Computing Services and Data Transfer Fees View
R2017-01 Request for Ruling Regarding the Taxability of a Product Fee Either As a Paid Monthly or Annual Subscription or As a Free One-Month Trial View
R2016-02 Request for Ruling Regarding the Taxability of Purchases Made by a Nonprofit Organization as it Awaits a Decision from the Internal Revenue Service on Their Application for Tax-Exempt Status View
R2016-01 Request for Ruling Regarding the Application of the Exemption Provided by R.I. Gen. Laws § 44-18-30(11) for Purchases of Medical Devices View
R2015-01 Request for Ruling Regarding the Inclusion of LLC Interests in a Decedent's Rhode Island Gross Estate View
R2012-02 Request for Ruling Regarding the Application of the Marital Deduction for the Estate of B as Provided by RIGL §42-35-8 View
R2012-01 Request for Ruling Regarding the Exemption of Certain Tangible Personal Property, Utilities, and Machinery and Equipment used in the Process of Manufacturing as Provided by RIGL §44-18-30(7)(i) and §44-18-30(22) View
R2011-01 Request for Declaratory Ruling Regarding the Applicability the Sales and Use Tax Law to Digital Certificate and Authentication/Resolution Services View
R2010-01 Request for Ruling Regarding Applicability of "Casual Sales" Treatment Under RIGL §44-18-20(d)(2) when Assets are Transferred Among Corporations in an Affiliated Group View
R2009-02 Request for Ruling Regarding the Applicability of the Sales/Use Tax Law to Commissions Paid to a Retailer by a Franchisor View
R2009-01 Request for Ruling Regarding Eligibility for a Credit from the Estate Tax for Tax Paid on Prior Transfers View
R2008-01 Request for Ruling Regarding Amendment or Extension of Ruling No. 2003-01 View
R2005-01 Request for Ruling Regarding the Application of the Jobs Development Act as Amended View
R2004-02 Request for Ruling Regarding the Qualification of Certain Corporations as Passive Investment Companies View
R2004-01 Request for Ruling Regarding Eligibility for the Investment Tax Credit View
R2003-04 Request for Ruling Regarding the Application of the Exemption provided by § 42-64-20(c) for Purchases of Certain Personal Property View
R2003-03 Request for Ruling Relating to Election of Marital Deduction for Qualified Terminable Interest Property ("QTIP") View
R2003-02 Request for Ruling Regarding the Application of the Exemption provided by § 42-64-20(c) for Purchases of Certain Personal Property View
R2003-01 Request for Ruling Regarding the Application of the Exemption provided by § 42-64-20(c) for Purchases of Certain Personal Property View
R2002-03 Request for Ruling Regarding the Application of the Exemption provided by §42-64-20(c) for Purchases of Certain Personal Property View
R2002-02 Request for Ruling Relating to the Application of the Exemption provided by §45-37.1-9 of the Rhode Island General Laws View
R2002-01 Request for Ruling Relating to the Application of the Exemption provided by §42-64-20(c) for Purchases of Certain Personal Property View
R2001-01 Request for Ruling Regarding the Application of the Jobs Development Act to the Hiring of Certain Employees in Rhode Island View
R2000-03 Request for Ruling Relating to the Application of the Sales/Use Tax Law to the Construction of an Electric Power Plant and Ancillary Equipment View
R2000-02 Request for Ruling Relating to the Exemption from Sales/Use Tax Under the Rhode Island Industrial Facilities Act, RIGL 45-37.1-1 View
R2000-01 Request for Ruling Regarding the Application of the Jobs Development Act to the Hiring of Certain Employees in Rhode Island View
R1999-03 Request for Ruling Regarding the Application of the Sales/Use Tax Law to Certain Lease Transactions View
R1999-02 Request for Ruling Regarding the Application of the Sales/Use Tax Law to Delivery of a Vessel in Rhode Island View
R1999-01 Request for Ruling Regarding the Application of the Exemption Provided by R.I.G.L. §42-64-20(c) for Purchase of Certain Personal Property View
R1998-02 Request for Ruling Regarding the Application of the Casual Sales Provision of the Sales/User Tax Law to a Bulk Sale of Assets View
R1998-01 Request for Ruling Regarding the Application of the Exemption Provided by R.I.G.L. 45-37.1-9 for Purchases of Certain Personal Property View
R1997-07 Request for Ruling Regarding the Application of the Investment Tax Credit View
R1997-06 Request for Ruling Regarding Cash Discounts Allowed and Taken on Certain Sales View
R1997-05 Request for Ruling Regarding the Application of the Exemption provided by R.I.G.L. 42-64-20(C) Purchases of Certain Personal Property View
R1997-04 Request for Ruling Regarding Use of Automobiles for Demonstration and Display View
R1997-03 Request for Ruling Regarding Cash Discounts Allowed and Taken on Certain Sales View
R1997-02 There is no Declaratory Ruling number 97-02. We inadvertently jumped from 97-01 to 97-03.
R1997-01 Request for Ruling Regarding the Application of the Exemption provided by R.I.G.L. 42-64-20(C) Purchases of Certain Personal Property View
R1996-04 Application of the Exemption Provided by R.I.G.L. Section 42-64-20(c) for Purchases of Certain Personal Property View
R1996-03 Withholding on Amounts of Convenience Federal Withholding Requested by Employee View
R1996-02 Application of the Exemption Provided by R.I.G.L. Section 42-64-20(c) View
R1996-01 Investing in a Certain Fund View
R1995-05 Credit for Qualified Research Expense View
R1995-04 Tax Exempt Status of a Municipal Bond Fund View
R1995-03 Sales of Assets under the Gross Earnings Tax View
R1995-02 Bulk Transfer of Assets under the Sales/Use Tax Law View
R1995-01 Sales/Use Tax on Boats View
R1994-05 Taxation of Bibles & Other Canonized Scriptures View
R1994-04 Taxation of Bibles & Other Canonized Scriptures View
R1994-03 Taxation of Bibles & Other Canonized Scriptures View
R1994-01 Taxation of Bibles & Other Canonized Scriptures View
R1993-06 Sales Tax - Water Quality Protection Charge View
R1993-05 Taxation of Lottery Winnings View
R1993-04 Sales/Use Tax Membership in a Travel Plan View
R1993-03 Sales/Use Tax - Informational Brochures View
R1993-02 Sales/Use Tax - Construction of Pumping Station View
R1993-01 Modifications Reducing Federal AGI View
R1992-08 Sale of Catered Food to Airline View
R1992-07 Disposition of Tangible Personal Property by a Public Corporation View
R1992-06 Sales/Use Tax on Pharmaceuticals View
R1992-05 Sales/Use Tax on Pastry Products View
R1992-04 Election to Pay Sales/Use Tax on Purchase of Tangible Personal Property View
R1992-03 Purchase of Assets of Certain Financial Institutions View
R1992-02 Purchases Under Hard-to-Dispose Materials Laws View
R1992-01 Purchases from Out-of-State Vendors View