Franchise and Excise Taxes
The rulings provided here are based on the particular facts and circumstances presented and are an interpretation of the law at a specific point in time. The law may have changed since a ruling was issued, possibly rendering it obsolete. These rulings have been redacted and are provided solely for informational purposes, and are not intended as statements of departmental policy. Taxpayers should consult with a tax professional before relying on any aspect of the rulings provided below.
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2012 | 2011 | 2010 | 2008 | 2007 | 2006 | 2005 | 2004 | 2002 | 2001 | 2000 | 1999 | 1998 | 1997 | 1996 | 1995 | 1994
- 12-17 - Job Tax Credit Carryforward (October 2012) - Posted 11/19/12
- 12-26 - Non-profit Status of Subsidiary LLC (November 2012) - Posted 1/8/13
- 12-27 - Out-of-State Licensing of Patents to In-State Affiliated Entities (November 2012) - Posted 1/8/13
- 12-32 - Net Earnings or Loss "Intangible Expenses" - Trade Accounts receivable (December 2012) - Posted 1/8/13
- 11-03 - Movie or Episodic Television Program Expense Credit (January 2011) - Posted 7/15/11
- 11-07 - Industrial Machinery Credit/Qualified HQ Facility (March 2011) - Posted 12/7/11
- 11-08 - Jobs Tax Credit/Qualified HQ Facility (March 2011) - Posted 12/7/11
- 11-10 - Qualified Data Center (March 2011) - Posted 12/7/11
- 11-11 - Commingled Trusts (February 2011) - Posted 8/12/11
- 11-17 - Job Tax Credit (June 2011) - Posted 2/22/12
- 11-26 - General Partnership Treatment (June 2011) - Posted 8/12/11
- 11-42 - Series LLC's (September 2011) - Posted 11/1/11
- 11-43 - FONCE Exemption and Custodial Account (September 2011) - Posted 10/17/11
- 11-44 - Discharge of Indebtedness in Bankruptcy (September 2011) - Posted 10/7/11
- 11-45 - IRC Section 754 Election (September 2011) - Posted 10/17/11
- 11-46 - Corporate Reorganization (September 2011) - Posted 10/11/11
- 11-53 - Corporate Reorganization (September 2011) - Posted 11/1/11
- 11-55 - Securization of Debt Obligations (October 2011) - Posted 11/16/11
- 11-63 - FONCE Exemption and Commodity Futures Contracts - Posted 12/19/11
- 11-66 - Public Law 86-272 (December 2011) - Posted 1/4/12
- 10-01 - ERISA and LLC Owned by SEP IRA (January 2010) - Posted 5/5/11
- 08-07 - Family-owned Non-Corporate Entity Exemption--Limited Partnership Partly Owned by Grantor Trust (February 2008)
- 08-14 - Tax Treatment of Business Trusts/Limited Liability Companies Wholly-owned by Business Trust Disregarded for Federal Income Tax Purposes (February 2008)
- 08-20 - Obligated Member Entity Following Reorganization (March 2008)
- 07-02 - Qualifying Investment Securities - Commodities Futures Contracts (January 2007)
- 07-09 - Qualification as a Hospital Company (March 2007)
- 07-11 - Exemptions for Providers of Low-income Housing (April 2007)
- 07-14 - Use of NOLs Upon Dissolution, Merger, Conversion or Reorganization (May 2007)
- 06-01 - Tennessee Excise Tax Treatment of Income Recognized Under the Profit Split Method of IRC Section 936(h)(5)(C)(ii) (January 2006)
- 06-06 - Pass-through Income (LOSS) - Treatment When Already Reported/Taxed (March 2006)
- 06-08 - Minimum Measure - Deduction of Expenses From Annual Rent (April 2006)
- 06-18 - Apportionment--NEXUS In Foreign States (May 2006)
- 06-20 - Net Operating Loss Carryovers After Conversion From Corporation to LLC (June 2006)
- 06-25 - C Corporation's NOLs and the 26 USC Section 338(h)(10) Election (July 2006)
- 06-26 - Survival of NOL in Merger Involving Disregarded Single Member LLC (September 2006)
- 06-27 - Financial Institutions--Doing Business in Tennessee and Combined Returns (July 2006)
- 06-28 - Net Earnings and Deduction of Expenses for Licensing Intangibles (July 2006)
- 06-34 - Family-owned Non-corporate Entity Exemption and Provision of Services (September 2006)
- 06-35 - Net Earnings and Deduction of Expenses for Licensing Intangibles (September 2006)
- 05-07 - Qualified Subchapter S Subsidiary (January 2005)
- 04-01 - Limited Liability Company and Holding Subsidiary (January 2004)
- 04-12 - Apportionment--Drop Shipments (April 2004)
- 04-12 - Franchise Excise Tax Apportionment Drop Shipments (April 2004)
- 04-22 - Job Tax Credit (July 2004)
- 04-29 - Limited Liability Companies--Exemption Under Tenn. Code Ann. Section 67-4-2008(a)(8) (September 2004)
- 02-05 - Application of Excise Tax to Family-owned Non-corporate Entities (March 2002)
- 02-09 - C Corporation Merged Into LLC (April 2002)
- 02-16 - Financial Institutions--NEXUS, Unitary Business, Sourcing of Receipts (June 2002)
- 02-22 - Doing Business in Tennessee (July 2002)
- 02-25 - LLCs--Exemption (August 2002)
- 02-28 - Products Stored in Tennessee Warehouse (August 2002)
- 02-31 - Venture Capital Fund Exemption (September 2002)
- 02-38 - Apportionment--Sourcing of Royalty Income (October 2002)
- 01-01 - Family Owned Entity (January 2001)
- 01-06 - Rent and Subrent Offsets (May 2001)
- 01-07 - Free Trade Zone Sales-Excise Tax Liability (May 2001)
- 01-24 - Distribution of Assets - IRC Section 338(h)(10) (October 2001)
- 00-08 - Limited Partnership--Investments Held Outside Tennessee (March 2000)
- 00-10 - Limited Partnership--Owning Stock in Tennessee Corporation (April 2000)
- 00-11 - Limited Partnership--Effective Date of Public Chapter 406, Sections 3 AND 4, of the Public Acts of 1999 (April 2000)
- 00-22 - Financial Institutions--Doing Business in Tennessee (July 2000)
- 00-23 - Financial Institutions--REIT--Classification and Filing Requirements for a Unitary Group (July 2000)
- 00-33 - Venture Capital Fund Exemption (September 2000)
- 99-09 - NEXUS--Leasing Real Property (March 1999)
- 99-13 - Certificate of Authority--Not-for-profit (April 1999)
- 99-32 - Foreign Corporation-Treaty-free Trade Zone (December 1999)
- 98-02 - Real Estate Investment Trusts--Separate Entity Classification of Subsidiaries and Doing Business in Tennessee (January 1998)
- 98-12 - Financial Institutions--Apportionment (March 1998)
- 98-31 - Financial Institutions--Classification, Second Tier Subsidiary (July 1998)
- 98-32 - Jobs Tax Credit--Product Service Center (July 1998)
- 98-33 - Business Trust--Treated as a Separate Entity From Certificate Holder (July 1998)
- 98-43 - Financial Institutions--Classification and Taxation of Limited Liability Companies (October 1998)
- 98-46 - Real Estate Investment Trusts--Classification, NEXUS and Taxation (November 1998)
- 98-47 - Limited Liability Company and a Corporate Member (December 1998)
- 97-01 - Employee Retirement Security Act (ERISA) (January 1997)
- 97-04 - Doing Business in Tennessee--Corporate Officer Living in Tennessee (February 1997)
- 97-15 - NEXUS for Tax Purposes--Doing Business in Tennessee (June 1997)
- 97-16 - NEXUS for Tax Purposes--Doing Business in Tennessee (June 1997)
- 97-19 - Financial Institutions--Apportionment (June 1997)
- 97-28 - Industrial Machinery Excise Tax Creadits--Transfer of Assets (July 1997)
- 97-30 - Retail Facility Built on State Line (July 1997)
- 97-41 - Limited Liability Companies--Chick-the-box Provisions (October 1997)
- 97-49 - Corporate Partners and Partnerships--Doing Business in Tennessee and Filing Requirements (December 1997)
- 97-56 - Liquidation--Accounting Period and Filing Requirements Following Sale of Assets (December 1997)
- 97-57 - Corporate Limited Partners--Doing Business in Tennessee (December 1997)
- 97-58 - Corporate Limited Partners--Doing Business in Tennessee (December 1997)
- 97-59 - Financial Institutions--Second Tier Subsidiaries (December 1997)
- 97-63 - Limited Liability Company--Taxability of an LLC and a Corporate (December 1997)
- 96-14 - Loss Carrovers From Barred Years (April 1996)
- 96-15 - Corporate Partners--Reporting Requirements for Limited and General Partners (April 1996)
- 96-16 - Doing Business in Tennessee--Customers in Tennessee (April 1996)
- 96-22 - Liquidation--I.R.C. Section 337 Transaction (June 1996)
- 96-34 - Financial Instututions--Apportionment Classification and Filing Requirements (November 1996)
- 96-36 - Financial Institutions--Apportionment Classification and Filing Requirements (December 1996)
- 95-02 - ERISA Pension Plan Subsidiary (January 1995)
- 95-05 - Apportionment--Sales Factor (February 1995)
- 95-06 - Franchise Excise Tax Liability of Corporate General Partner in Limited Partnership (February 1995)
- 95-15 - Corporate Partners--General, Limited and Apportionment Formula (May 1995)
- 95-21 - Corporate Limited Partners--Doing Business in Tennessee (June 1995)
- 95-22 - NEXUS for Tax Purposes--Doing Business in Tennessee (June 1995)
- 95-27 - Apportionment--Goods Shipped Out-of-state Location (July 1995)
- 95-39 - Financial Institutions--Classification, Returns Required and Apportionment (November 1995)
- 95-42 - Corporate Limited Partners--Doing Business in Tennessee (December 1995)
- 94-01 - Doing Business in Tennessee (January 1994)