The Regulatory Services Branch of the Division of Taxation will be issuing and publishing Letter Rulings and Technical Advisory Memorandums to further support and advance the Treasurer's effort to establish a more formal structure of guidance to assist tax practitioners and taxpayers alike.
A Letter Ruling (LR) is a written determination issued on behalf of the Director based on the law, regulations and Division policies in effect as of the date the Letter Ruling is issued or for the specific time period at issue in the Letter Ruling. A Letter Ruling is limited to the facts set forth therein and is binding on the Division of Taxation only with respect to the person or entity to whom it is issued and only if the person or entity fully and accurately describes all relevant facts. A Letter Ruling cannot be used as legal precedent but may be utilized as guidance by any other like-situated taxpayers. Please see the Division's Notice How to Obtain a Letter Ruling from the Division of Taxation.
Technical Advisory Memorandums (TAMs) may be utilized as guidance but are not binding on the Division. Technical Advisory Memorandums are modeled after Regulatory Service Branch responses to taxpayer inquiries that raise issues of broad application.
Technical Bulletins (TBs) are published to provide technical guidance on the Division’s interpretation of the law, regulations, and policy.