Tax Policy Updates - April 2025

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Information about the recent activities of the Office of Tax Policy is provided below. This information includes new and revised publications, rulemaking activities, and recently published letter rulings and information letters.

New and Revised Publications

Recently Published Private Letter Rulings (PLR) and General Information Letters (GIL)

  • GIL 25-001 – Residential Energy Storage System Tax Credit - For the purpose of the income tax credit for residential energy storage systems, the purchase price of the “energy storage system” does not include the cost of the “on-site generation.”
  • PLR 24-008 – Sourcing Sales When Customer Arranges for Third-party Shipping – A sale is sourced to the known location of the purchaser when the purchaser arranges for and hires a third-party shipping company to take possession of the property at the business location of the seller and deliver it to the purchaser.
  • GIL 24-005 – Taxability of Franchise Fees – Franchise fees are not among the statutory list of fees excluded from the purchase price and thus are subject to state sales tax as part of the purchase price.