Virginia State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Virginia, with full citations and the original source on every page.
No Virginia rulings match these filters
Try a different search term or clear the filters.
Could a city require a second BPOL license when a growing service business moved employees to a second city location?
Yes. The second office conducted regular, continuous, nonancillary service activity for more than 30 days, making it a separate definite place of business. The city could require a second license and …
Was electronic catalog data conversion manufacturing for BPOL tax, and could a county default to payroll to situs receipts?
Virginia classified the county operation as a business service, not manufacturing, because it reformatted and indexed data without substantially changing its character and did not sell goods at wholes…
Did a petroleum marketer have a definite place of business, and therefore BPOL liability, at a third party's city terminal?
No. Virginia found that the petroleum marketer neither leased terminal facilities nor maintained a definite place of business in the city. Its throughput agreement bought temporary commingled storage …
Could the Tax Commissioner reduce estimated city BPOL and meals-tax assessments for a caterer with incomplete records?
Only the BPOL issue could be considered administratively. The Tax Commissioner lacked authority over the city's meals-and-beverage tax. For BPOL, the caterer had not disproved the estimated receipts, …
Were maritime-crane modification, repair, and transport activities contracting or a business service for Virginia BPOL tax?
They were business services. The cranes were machines and tangible personal property rather than real-property structures, so modifying and repairing them was not contracting for BPOL purposes. Transp…
Did fuel stored and lifted at a third-party city terminal create BPOL liability and a late penalty for a petroleum wholesaler?
No. The petroleum business's throughput agreement provided temporary commingled storage and distribution services, not leased premises. With no office, staff, records, continuous presence, or advertis…
Did shared individual ownership and a management agreement make medical-service companies one affiliated group for the BPOL receipts exemption?
No. The companies lacked the required direct stock-ownership relationship with the medical group. An individual's ownership and a management agreement did not create statutory affiliation, so receipts…
Could a city apply its grandfathered three-percent telephone BPOL rate to a cellular PCS provider that did not offer landline local-exchange service?
No. The PCS provider was a telephone company, but the city's grandfathered three-percent rate applied only to the local-exchange landline service covered by its 1972 ordinance. The city could apply th…
Did the BPOL exemption for a title insurance agent cover separate real estate settlement-service receipts unrelated to insurance premiums?
No. The exemption protected title-insurance agency activity tied to the insurance company's direct gross premium income, not the agent's separate settlement and other noninsurance services. Virginia u…
How should a disregarded LLC calculate Virginia BPOL receipts when its corporate owner reports the LLC's out-of-state business on income tax returns?
The LLC could deduct its own receipts from business in jurisdictions where its corporate owner filed an income or income-like tax return reporting those receipts. It had to start with worldwide receip…
Did occasional short-term rental of an owner's second home owe BPOL tax, and did the Virginia Tax Commissioner decide the transient occupancy tax?
The private-home rental was exempt from BPOL tax. The Tax Commissioner did not decide whether transient occupancy tax was due because that tax fell outside the Commissioner's advisory jurisdiction; th…
Could a media-buying business exclude client money paid to media vendors from BPOL gross receipts as pass-through agency funds?
No. The business did not prove contracts linking clients and vendors, did not document a separate or fiduciary accounting system, and reported the client payments as federal gross income with vendor c…
Did an automotive alternator remanufacturer qualify as a manufacturer whose wholesale sales from the place of manufacture were exempt from local BPOL tax?
Yes. Virginia found no basis to reverse its earlier manufacturer classification because alternators were rebuilt at the county facility and the subsidiary was integrated with its manufacturer's busine…
Could a business obtain separate retail and wholesale BPOL treatment without records reconciling its claimed wholesale receipts to tax returns?
Not on the evidence submitted. The county could not reconcile the claimed wholesale activity to the business's federal and local returns, and the taxpayer supplied no contrary proof on appeal. The ret…
Browse Virginia rulings by topic
These are official tax letter rulings and advisory opinions issued by Virginia'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.