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 …
Did Louisiana preserve corporate charitable contributions that federal law converted into a net operating loss carryover?
No. Louisiana used its own net operating loss rules and recognized the charitable deduction only when taken on the federal return, so the portion converted to a federal NOL carryover was lost for Loui…
How did Louisiana allocate the former IRC § 199 domestic production activities deduction among affiliated corporations and Louisiana income classes?
Louisiana used the federal allocation to each affiliated-group member, then divided that member's deduction among allocable, apportionable, and untaxed income based on QPAI. No deduction was allowed f…
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…
How did Louisiana treat a corporate owner's single-member LLC that had not elected federal corporate tax status?
Louisiana followed federal treatment: the LLC was a disregarded division of its corporate owner, and its assets, liabilities, income, deductions, and credits belonged on the owner's return. Nexus of e…
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…
How did Louisiana conform to the 2002 federal 30% first-year depreciation deduction and five-year net-operating-loss carryback?
Both individuals and corporations followed the federal 30% first-year depreciation provision. Individuals followed the federal five-year NOL carryback for the covered 2001 and 2002 loss years, but cor…
Could a Louisiana corporation deduct expenses allocated to an IRC § 78 foreign-dividend gross-up that Louisiana excluded from corporation income tax?
No. The gross-up was income for Louisiana purposes but was specifically excluded from tax, so expenses attributed to that untaxed income were disallowed in computing Louisiana taxable income.
Did Louisiana apply a throwback rule to a Louisiana corporation's sales into a state where P.L. 86-272 prevented income taxation?
No. Louisiana had not enacted UDITPA's throwback approach, so its corporation income- and franchise-tax statutes did not return those sales to Louisiana merely because the destination state could not …
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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.