Illinois State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Illinois, with full citations and the original source on every page.
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How does Illinois tax fabricated structural steel sold without installation, incorporated under a construction contract, or shipped out of state?
It depends on the product, design work, contract, and delivery. A fabricated item substantially similar to stock or standard property produced Retailers' Occupation Tax on the full selling price witho…
How did Illinois treat an out-of-state repair manager that hired local contractors for plumbing, electrical, painting, and building repairs?
Illinois did not expressly decide the repair manager's nexus or final tax liability. It explained that contractors permanently incorporating property into real estate were end users owing Use Tax on c…
How did Illinois analyze sales tax, service tax, nexus, and voluntary disclosure for an out-of-state repair dispatcher using Illinois contractors?
Illinois did not expressly decide the repair dispatcher's nexus or final tax liability. It explained that construction contractors were end users owing Use Tax on materials permanently incorporated in…
Why did Illinois sales tax appear on mail-order prescription drugs, and how did a pharmacist calculate and collect that tax?
Qualifying drugs, medicines, and medical appliances were taxed at a reduced 1% Illinois state rate plus applicable local taxes; items not qualifying for the reduced rate used the 6.25% general-merchan…
Are engineering and design charges for custom bridges taxable in Illinois, and what if engineering is sold without tangible property?
It depends on the bridge transaction. If the bridge was a retail sale, separately stated engineering and design were costs of doing business included in taxable gross receipts. If the bridge met all s…
Are aircraft repair and maintenance services or the parts transferred with them exempt from Illinois tax?
Unresolved for the requester. Illinois could not determine the treatment because the letter did not identify the exact service or maintenance work or the aircraft parts involved. A service with no tra…
How do Illinois Service Occupation Tax rules apply to custom-printed loyalty cards stored in Illinois and later drop-shipped nationwide?
Unresolved for the exact loyalty-card transaction. Illinois did not directly answer whether tax attached when ownership changed in Illinois, whether later drop-ship and freight fees were taxable, whet…
Did Illinois confirm a print broker's de minimis serviceman status, 50%-of-bill method, and interstate-commerce exemption for direct mail?
No. ST 11-0047-GIL declined to issue a Private Letter Ruling and did not confirm the print broker's de minimis-serviceman classification, use of 50% of the service bill as the tax base, or interstate-…
Could an Illinois pharmacy fill prescriptions tax-free when a tax-exempt health center paid for uninsured patients?
Potentially. ST 11-0039-GIL says drugs sold to an organization holding an Illinois exemption identification number could be sold free of tax; without an E number, the sale could not be tax-free. The p…
Who owed Illinois tax when an out-of-state facilities manager hired Illinois construction contractors and service providers for retail stores?
Construction contractors were end users of materials permanently incorporated into Illinois real estate and owed Use Tax on their cost. When subcontractors acted as construction contractors, the gener…
How did Illinois tax media postproduction, film or videotape duplication, and electronic transmission services?
Pure services without a transfer of tangible personal property were outside Retailers' Occupation, Use, Service Occupation, and Service Use Tax. When film, videotape, or other tangible media was trans…
Did Illinois classify a trade-show company's service, lease, telecom, and catering revenue items as taxable or nontaxable?
Not item by item. ST 11-0014-GIL declined the requested taxable-or-nontaxable classifications and supplied general rules. Pure services without transferred tangible property were outside Service Occup…
Were custom-printed checks and deposit tickets sold by a bank subject to Retailers' Occupation Tax or Service Occupation Tax?
Generally Service Occupation Tax for genuinely custom print items. ST 10-0124-GIL says a special-order product of general utility that performs substantially like a stock item was a taxable retail sal…
Were automobile-dealer direct-mail program fees subject to Illinois Retailers' Occupation Tax?
Apparently not under Retailers' Occupation Tax. ST 10-0122-GIL says there did not appear to be Retailers' Occupation Tax liability on the program fees billed by the automobile company to participating…
How did Illinois tax prescription eyeglasses and contact lenses transferred by an optometrist?
Prescription eyeglasses and contact lenses were medical appliances eligible for the lower State rate described in the 2010 GIL. An optometrist rendering professional services did not owe Retailers' Oc…
Did reselling access to an online employability assessment create Illinois sales or service tax when no property was transferred?
Generally no under the facts stated. ST 10-0111-GIL says a transaction with no transfer of tangible personal property created neither Retailers' Occupation Tax, Use Tax, Service Occupation Tax, nor re…
Were consumable items bought by a residential-service provider exempt merely because Medicaid recipients used them?
No blanket exemption applied merely because Medicaid recipients consumed the items. Direct Medicare or Medicaid payments could be exempt as governmental purchases when supported by an active E-number,…
Did Illinois decide whether an out-of-state eye-monitoring service with devices in patients' homes had nexus or owed tax on its monthly service fees?
Unresolved. The Department did not decide nexus, registration, or the taxability of the monthly eye-monitoring service. It outlined four Service Occupation Tax or Use Tax methods for property transfer…
How did Illinois treat call-tracking services that electronically delivered reports and used toll-free numbers?
If no tangible property was transferred, the service produced no Retailers' Occupation or Use Tax under the general rule, and electronic data was not tangible property. A provider using—but not resell…
Did Illinois approve a service-company tax matrix, and how did it explain tax on property transferred with services, electronic data, software, and equipment leases?
No. Illinois would not approve the private tax matrix. It explained that services with no tangible-property transfer generally produced no Retailers' Occupation or Use Tax, while property transferred …
When was a custom bridge-control system treated as special-order property subject to Service Occupation Tax rather than a taxable retail sale?
A special-order machine was treated as a service transaction only if all three tests were met: the buyer primarily hired the seller's engineering or scientific skill; the property had value only for i…
How did Illinois tax a medical-record retrieval service that delivered records on paper, by fax, or electronically as PDFs?
Medical-record retrieval appeared to be a service. Electronically viewing, downloading, or transmitting text and data—including PDF delivery—was not a tangible-property transfer and was outside the fo…
Did Illinois's interstate-commerce exemption apply when exhibit property shipped out of state was expected to return to Illinois for repair or remodeling?
No, if the return was known when the sale was made. The exemption required the serviceman to be obligated to deliver the property from Illinois to a point outside Illinois and for the property not to …
How did Illinois treat custom printed bills and notices, electronic billing data, and software used in those services?
Custom print items that could not be sold to another buyer at substantially the same price generally fell under Service Occupation or Use Tax rather than Retailers' Occupation Tax. Electronically tran…
Who owed Illinois tax when a janitorial company used cleaning supplies while providing services?
The janitorial provider owed Use Tax on the cost price of cleaning supplies it consumed while performing the service, and it could not buy those supplies for resale. The customer generally owed no tax…
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These are official tax letter rulings and advisory opinions issued by Illinois's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.