Louisiana State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Louisiana, with full citations and the original source on every page.
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How did Louisiana treat property and sales connected with a Louisiana foreign trade zone in the corporation income- and franchise-tax ratios?
Income tax treated all corporeal movable property physically in the zone as outside Louisiana; franchise tax did so only for property imported from outside the United States. Sales delivered into the …
How does Louisiana's Motion Picture Investor Tax Credit work — who can earn it, can it be transferred and sold, and how is it applied to a tax bill?
It answers common questions about the film Investor Tax Credit under La. R.S. 47:6007: any investor that is not itself a production company (even a tax-exempt one) can earn it, the credit is freely tr…
Did a Texas LLC become subject to Louisiana corporation franchise tax merely because it elected federal and Louisiana corporation-income-tax treatment?
No. The check-the-box election controlled corporation income-tax treatment but not franchise-tax classification. The LLC remained treated as a limited partnership for franchise tax and therefore was n…
How did Louisiana treat capitalized lease assets in the corporation franchise-tax and income-tax property factors?
Franchise tax treated a genuine lease as a rental, excluding the asset from the lessee's property factor. Income tax followed federal ownership: include the asset when the lessee was federally treated…
Was an oil and gas corporation commercially domiciled outside Louisiana even though it maintained a Louisiana administrative and operations office?
Yes. Looking at actual commercial practices as a whole, the corporation was directed and managed from its out-of-state headquarters, where strategic deals, executive approvals, governance, finance, ba…
Was a certified Louisiana health maintenance organization exempt from corporation income and franchise taxes because it paid the annual HMO license tax instead?
Yes. The organization met the HMO definition, held the Insurance Commissioner's certificate, earned most revenue from member health services, and paid the annual premiums tax. The annual license tax a…
Did an out-of-state-chartered bank paying Louisiana bank shares tax qualify for the same corporation income- and franchise-tax exemptions as Louisiana banks?
Yes. The Department interpreted the exemptions to cover every bank paying the bank shares tax, avoiding unconstitutional discrimination after interstate branch banking became legal. The bank could cla…
Was federal gasoline excise tax passed through in the consumer price included in Louisiana corporation income- and franchise-tax sales ratios?
Yes. The federal tax was imposed on the producer, not collected from the customer on the government's behalf. Passing that cost through—even as an itemized amount—was sales revenue included in both ra…
In which income-tax and franchise-tax periods did a taxpayer claim Louisiana's inventory tax credit?
For income tax, the credit belonged to the period when the inventory tax was paid, not the assessment year. For franchise tax, the payment entered the immediately following franchise-tax period becaus…
Did an entity's federal Form 8832 election to be taxed as a corporation determine whether it was subject to Louisiana corporation franchise tax?
No. A check-the-box election established federal income-tax treatment, not the entity's actual legal form, and had no significance in deciding Louisiana franchise-tax liability under the ruling.
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These are official tax letter rulings and advisory opinions issued by Louisiana'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.