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Alabama tax treatment of business entity conversion of a Delaware corporation to a single member Delaware limited liability company located and doing business in Alabama and Georgia.

Alabama tax treatment of business entity conversion of a Delaware corporation to a single member Delaware limited liability company located and doing business in Alabama and Georgia.

A Revenue Ruling is issued at the request of a person or entity. It is limited to the facts set forth therein and is binding on the department and the state, its political subdivisions, and taxing authorities only with respect to the taxpayer making the request and only with respect to the facts contained in the request. A Revenue Ruling describes the substantive application of any law or rule administered by the department as of the date the Ruling is issued. Subsequent changes in the law, administrative rules, judicial decisions, Tax Tribunal decisions, or changes in department policies could affect the validity of the information presented in a Revenue Ruling.

Revenue Ruling/Procedure NumberSubject of RulingDate of RulingDownload
1992-001Purchase of replacement equipment exempt from ad valorem tax under Tax Incentive Reform Act1993-03-22Download
1993-001 REVOKED (Issue 1 only) 1) Exception to the “Throwback Rule” for distortion of company’s overall apportionment factor; 2) Company’s proper franchise tax classification1993-02-12Download
1993-002 Proposed expenditures to control, reduce, or eliminate air and water pollution: (a) exempt from sales/use tax; (b) exempt from property tax; (c) deductible from capital employed in state for foreign franchise tax purposes; (d) deductible for income tax purposes.1993-10-12Download
1993-003Entry fees paid by participants in national tournament that are returned to participants as prize money not subject to sales tax1993-11-30Download
1993-004 REVOKEDBusiness trust (qualifies as an REIT under I.R.C. § 856) taxed as ordinary trust for state income tax purposes1993-08-10Download
1993-005 REVOKED In computation of domestic share tax, corporation not allowed to deduct its allocable share of assessed value of a limited partnership of which it is a general partner1993-08-10Download
1993-006 REVOKEDBusiness trust: (a) subject to foreign franchise tax imposed on foreign corporations; (b) not subject to domestic franchise tax or the domestic share tax since does not have capital stock1993-08-10Download
1993-007 REVOKED Dividend and interest income distributed to nonresident beneficiaries of Alabama business trust (who have no other contacts with the state for tax purposes) not taxable in Alabama1993-08-10Download
1993-008Property used in distribution of motor vehicle supplies, accessories, tools, equipment and new motor vehicle parts qualifies for abatement of ad valorem and construction related transaction taxes for private use industrial property1993-08-03Download
1993-009 “Ratites”, any of a group of flightless birds such as ostriches and emus, entitled to same favorable tax treatment given to poultry under the tax statutes; includes particular exemptions from sales and use tax statutes and exemption from ad valorem taxation.1993-12-07Download
1993-010Funds and value of property received in exchange for corporation’s agreement to locate plant site in Alabama are gifts and exempt from Alabama corporate income tax1993-09-24Download
1993-011Abatement of taxes applicable to transactions between company and Industrial Development Authority, including: deed recording taxes, mortgage recording taxes, sales and use taxes on manufacturing equipment and construction materials, ad valorem taxes, income tax deductions for rental payments to IDA, lease tax; commencement of construction pursuant to agreement and its effect on abatement rulings.1993-10-25Download
1993-012 Taxpayer allowed deduction for franchise tax purposes for amount invested by it in bonds issued by city’s Industrial Development Board; rental payments made by Taxpayer to Board not deductible as interest on bonds in computing its net income1994-01-28Download
1993-013 Implied waiver of written notice to renew lease is properly exercise option to renew, and entitles the property to continued tax-exempt status pursuant to ad valorem tax regulation 810-4-3-02(8).1993-01-14Download
1994-001Financial investment in Alabama by a foreign corporation as a limited partner is not “doing business” in state such that it subjects the corporation to state franchise taxes; exempt from Alabama income tax because the entity qualifies as exempt entity under I.R.C. § 401(a)1994-02-17Download