Rhode Island State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Rhode Island, with full citations and the original source on every page.
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Were a utility's purchase and simultaneous Rhode Island resale of a self-unloading bulk-carrier vessel subject to sales or use tax?
No. Rhode Island's exemption for the sale, storage, use, or consumption of new and used boats covered the bulk-carrier vessel. The utility's purchase from the current owner and simultaneous resale…
Could the Rhode Island Tax Administrator declare the sales-tax exemption for Bibles and other canonized scriptures unconstitutional?
No. The Tax Administrator refused to decide the constitutional challenge because questions about a statute's constitutionality are reserved to the judiciary. The order did not decide whether the…
Was the petitioner required to pay Rhode Island sales tax on a Bible purchase, and could the Tax Administrator decide whether the scripture exemption was unconstitutional?
The petitioner was required to pay sales tax under Regulation SU 92-136. The Tax Administrator would not decide whether R.I. Gen. Laws § 44-18-30(EE), which textually exempted canonized scriptures,…
Did the petitioner owe Rhode Island sales tax on a Bible under Regulation SU 92-136, and could the Tax Administrator decide the statute's constitutionality?
The petitioner was required to pay sales tax under Regulation SU 92-136. The Tax Administrator declined to decide whether the canonized-scripture exemption in R.I. Gen. Laws § 44-18-30(EE) was…
Was Rhode Island's water quality protection charge included in the taxable sales price of water?
Yes. The charge became part of the water's sale price when the supplier added it to the bill, so the retailer had to include it in gross receipts subject to sales tax. The 1993 order applied the…
Were installments received after July 1, 1989 from a Rhode Island Lottery prize won before that date subject to personal income tax?
Yes. Rhode Island taxed lottery winnings when received after July 1, 1989, regardless of the drawing or winner-determination date. The client's pre-1990 win did not preserve the former exemption for…
Were sales of travel-plan memberships through multilevel dealers subject to Rhode Island sales tax, and did the dealers need retail sales permits?
No. The memberships were intangible rights to travel discounts rather than tangible personal property, so Company and dealer sales were not taxable retail sales and the dealers did not need retail…
Did a company owe Rhode Island sales tax when it bought free tourism and advertising brochures from a Rhode Island printer, including copies later shipped out of state?
Yes. The company had to pay sales tax when purchasing the informational brochures from a Rhode Island printer, whether the copies were distributed in Rhode Island or later shipped out of state.…
Were a private developer's purchases of materials for a pumping station that would be dedicated to the Providence Water Supply Board exempt from sales or use tax?
No. The developer had no construction contract with the Water Supply Board or Town of Johnston and was not a subcontractor under an exempt entity's contract. Required dedication of the completed…
Could new Rhode Island residents use a California-tax basis instead of federal basis for IRC § 1042 replacement securities or claim a Rhode Island income modification on sale?
No. Rhode Island's personal income tax followed the taxpayers' federal § 1042 nonrecognition treatment and federal basis. California's earlier decision to tax the ESOP transaction did not create a…
Did a Warwick airline caterer have to collect sales tax on separately stated airport port fees added to its food invoices?
Yes. The caterer's gross receipts included both the food charge and the separately stated port fee passed through to the airline. Sales tax therefore applied to the total invoice amount, not just…
When did a tax-exempt public corporation have to pay or collect sales tax on repossessed property, receiver sales, and auctioneer sales?
The corporation paid no tax on property it acquired, but it had to collect tax when selling property for its own account because the purchaser bore the tax. It did not collect on court-approved…
Were all pharmaceuticals, including proprietary or over-the-counter medicines, exempt when sold for nursing-facility patients under physician prescriptions?
Yes. Pharmaceuticals meeting the statutory drug or medicine definition were exempt from Rhode Island sales and use tax when sold under a physician's prescription to nursing-facility patients. The…
Were plastic-wrapped trays of five or ten dozen mini-donuts and 18 or 36 muffins, marketed as party platters, exempt bakery products for home consumption?
No. Despite containing more than six bakery items, the plastic-tray packaging and 'party platter' marketing indicated immediate consumption at party occasions rather than later home consumption. The…
Were fees for remote database access, customer-site computer terminals, and telephone auto-parts information subject to Rhode Island sales tax?
Remote database access and telephone information fees were nontaxable services. Customer-site computer terminal fees were rentals, but no tax was due on the rental charges because Company elected…
How did Rhode Island treat a federally chartered bank's acquisition of failed credit-union assets, related DEPCO assistance, bank taxes, bulk-sale property, and parent nexus?
The ruling treated timely DEPCO aid as received by the credit unions before the asset sale, used purchase cost for asset basis, followed federal treatment for several income and debt items, imposed…
Was recycled or re-refined petroleum-based or synthetic lubricating oil subject to Rhode Island's hard-to-dispose materials tax when used as a lubricant?
No. Both the statute and Regulation LIT 90-2 expressly excluded recycled or re-refined petroleum-based and synthetic lubricating oil from the hard-to-dispose material definition. Later use as a…
Did a Rhode Island door company owe use tax on stock doors stored in Warwick, and were specialty doors for known out-of-state jobs exempt during temporary Rhode Island storage?
Stock doors were taxable because their final destination was unknown and Rhode Island inventory storage ended the interstate journey. Specialty doors for identified out-of-state customers were…
When are components purchased to construct or install solar arrays and wind turbines exempt under Rhode Island's renewable-energy-products sales-tax exemption?
A component was exempt under section 44-18-30(57) only if the same renewable-product manufacturer specified or sold it and it was consumed or incorporated into constructing or assembling the listed…
Did a Providence bookseller have to charge Rhode Island sales tax on each sale of Bibles and other canonized scriptures under Regulation SU 92-136?
Yes. The retailer had to charge and collect Rhode Island sales tax on every sale of a Bible or other canonized scripture under Regulation SU 92-136. The Tax Administrator declined to decide whether…
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These are official tax letter rulings and advisory opinions issued by Rhode Island'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.