Private Letter Rulings

General Information

What is a Private Letter Ruling?

A private letter ruling is a written, informational statement of the Commission's interpretation of statutes or administrative rules and their application to a particular set of facts or circumstances. A private letter ruling typically addresses unusual or complex questions pertaining to a particular taxpayer. Private letter rulings are governed by Utah Administrative Code R861-1A-34.

It should be noted, the Commission does not issue private letter rulings to answer routine tax questions.

Whom do I contact about a routine tax question?

Routine tax questions are generally answered by the Technical Research Unit of the Tax Commission. You may call the Technical Research Unit at (801) 297-7705. 

If you want a written answer to your Utah tax question, you may send a written request for the information to the Technical Research Unit by the following methods: 

Mail:

Technical Research Unit
Utah State Tax Commission
210 N 1950 W
Salt Lake City UT 84134-7000

Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

Fax: 801-297-6357

Please include the following with your request:

  1. your contact information,
  2. a statement that you are requesting a written answer to your question(s),
  3. a description of the facts and circumstances of your situation, and
  4. any other pertinent information.

What if I don’t know if it is a routine tax question?

The Commission suggests that you send your question to the Technical Research Unit. Technical Research Unit’s contact information is above. If the Technical Research Unit receives your request and concludes that your question cannot be answered using the Utah statutes, rules, or prior decisions, then the Technical Research Unit may forward your question to the Commission for the Commission to answer through a private letter ruling.

Can Private Letter Rulings be used in an appeal before the Commission?

Yes. If an appeal is filed subsequent to the issuance of a private letter ruling, the weight the Commission gives a private letter ruling in a subsequent appeal by the same taxpayer depends on the degree to which the underlying facts addressed in the private letter ruling were adequate to allow the Commission to thoroughly consider the issues and interests involved. Private letter rulings may be used in appeals by people other than the ones who requested the rulings; however, the weight the Commission gives the private letter rulings depends on the similarity of the facts presented in the appeals to the facts addressed in the private letter rulings.

The Commission will not issue a private letter ruling for any legal question also being addressed by an appeal pending before the Tax Commission.

How can I view previously issued Private Letter Rulings?

The public may research and view redacted copies of most private letter rulings through the Searchable Database of Private Letter Rulings, located on the tab above. To protect the privacy of the people who have requested private letter rulings, the Commission has removed confidential information from the private letter rulings before publishing them. If you are able to identify a person, entity, or subject property when reading a private letter ruling posted on this website, please notify the Tax Commission immediately at This email address is being protected from spambots. You need JavaScript enabled to view it..

What if I am sure I have a new question
about the interpretation of a statute as it applies to certain facts?

If you want a private letter ruling, you may mail your letter requesting a private letter ruling to the following address:

Office of the Commission
Utah State Tax Commission
210 N 1950 W
Salt Lake City UT 84134

Alternatively, you may fax your letter to 801-297-2292 or email it to This email address is being protected from spambots. You need JavaScript enabled to view it.. To help the Commission get your private letter ruling request processed efficiently and in a timely manner, we ask that you send an electronic copy of the private letter ruling request in a Microsoft Word format.

Your letter requesting a private letter ruling should be addressed to the "Commissioners" and should include the following information:

  • Your contact information
  • A statement that you are requesting a private letter ruling
  • A description of your facts
  • Your Utah tax question(s)
  • Other pertinent information

If you believe a particular answer to your tax question is correct, please also include the following:

  • A statement of what you think is the correct answer
  • The reasons you think that answer is correct

To see examples of request letters, you may view other private letter rulings through the Searchable Database of Private Letter Rulings, located on the tab above. Currently, there is no fee for you to request a private letter ruling from the Commission.

After the Commission receives your letter requesting a private letter ruling, the Commission will decide whether it will issue a private letter ruling to answer your tax question. If the Commission decides to issue a private letter ruling, the Commission will contact you and ask for a copy of your letter in Microsoft Word format if you have not already provided it. Also, the Commission may ask you additional questions about the facts you presented. Please keep the contact information you provide the Commission up-to-date. If the Commission decides not to issue a private letter ruling, your question may still be answered by the Technical Research Unit of the Tax Commission.

If you have additional questions about the procedures of private letter rulings or the status of your private letter ruling request, you may email your question to This email address is being protected from spambots. You need JavaScript enabled to view it. or call either Christa Johnson, Executive Assistant, at 801-297-3901 or Aimee Nielson-Larios, Administrative Law Judge, through her clerk at 801-297-3904.

Searchable Database

Searchable Database of Private Letter Rulings

Due to the number of rulings available, we can't offer a full listing. Instead, we've provided this database that includes rulings dating back to 1989. Hint: put your search phrase in "quotes" to search for an exact phrase.

If you are able to identify a person, entity, or subject property when reading a private letter ruling posted on this website, please notify the Tax Commission immediately at This email address is being protected from spambots. You need JavaScript enabled to view it..

Recent Rulings

Recent Private Letter Rulings

Click on headings to sort.

COM_FABRIK_ORDERPLR Number COM_FABRIK_ORDERResponse Date COM_FABRIK_ORDERSubject Matter
12-002 Dec 7, 2012 Utah Sales Tax Treatment of Sales of Access to Online News Service
12-005 Nov 28, 2012 Laboratory Testing Services Performed in Utah for Out-of-State Customers
12-008 Nov 26, 2012 Validity of a Paper-Filed Utah Tax Return Signed Through An Alternative Signature Method
12-006 Sep 4, 2012 Private Letter Ruling Request on the Application of the Utah Special Fuel Tax
11-007 Aug 16, 2012 Utah Sales Tax Treatment of Repair Services on Turbine Generators Located in Utah and Used to Generate Electricity for Sale
12-004 May 31, 2012 For Sales Tax Purposes, the Applicability of the Farming Operations Exemption Found in § 59-12-104(18) to Pipe Purchased by a Mutual Nonprofit Irrigation Company
11-005 Mar 21, 2012 Private Letter Ruling Request–Multi-Channel Audio and Video Service Tax Treatment of Certain Separately Stated Cable Charges
10-011 Feb 24, 2012 Sales Tax Treatment of Web-Based Remote Access Services
11-004 Jan 24, 2012 Applicability of Utah Admin. Code R865-9I-44 to a Nonresident Professional Athlete for the Situation Presented
11-006 Jan 12, 2012 Sales Tax Treatment of Sales of Online Services that Assist Human Resource Departments in the Job Application and Hiring Process
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