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ATTN: Tax Policy Division
P.O. Box 13528
Austin, Texas 78711-3528
General Information Letters and Private Letter Rulings
Taxpayers who have questions about Texas taxes can receive help from the Comptroller’s office through either a general information letter or a private letter ruling.
General information letters answer most questions, but taxpayers can request a private letter ruling.
The Comptroller views any written inquiry regarding a taxability issue as a general information letter request unless the inquiry meets the criteria of a private letter ruling request.
General Information Letters
A general information letter provides information and resources in response to a written question about the taxability of an item or transaction. Resources provided include tax laws, rules or publications.
General information letters are not binding on the Comptroller and cannot be relied on for detrimental reliance relief.
Request a general information letter by using our Texas Taxes Help form.
Private Letter Rulings
A private letter ruling is the Comptroller's written determination of how relevant tax laws, rules and policies apply to a specific set of facts. It is binding on the Comptroller, except as noted below and, if the taxpayer's identity is included in the request, the taxpayer can rely on the private letter ruling for detrimental reliance relief.
Specific information must be included when requesting a private letter ruling. See Rule 3.1, Private Letter Rulings and General Information Letters, before submitting a request to make sure all requirements are met. The Comptroller will request additional information as needed.
Request a private letter ruling by emailing tax.help@cpa.texas.gov or by mailing:
Texas Comptroller of Public AccountsATTN: Tax Policy Division
P.O. Box 13528
Austin, Texas 78711-3528
We will promptly acknowledge receipt of all private letter ruling requests.
When a Private Letter Ruling Will Not Be Issued
The Comptroller is not required to provide a response to a private letter ruling request if:
- the request does not meet the specific requirements;
- additional information requested by our office is not provided, including required information that was not provided in the original request; or
- the request relates to:
- an audit examination of any type;
- a refund request;
- a voluntary disclosure agreement;
- an administrative hearing; or
- litigation before the Comptroller for the same person (or a related person) and for the same or any previous tax period.
Binding Effect
Detrimental reliance applies to private letter rulings as provided in Rule 3.10, Taxpayer Bill of Rights, for the person or entity to whom or which the ruling request relates.
A person who receives a private letter ruling can rely on the ruling, prospectively from the date it is issued, with respect only to the particular issue and the person identified in the request.
For franchise tax purposes, a member of a combined group can rely on a private letter ruling issued to the reporting entity of a combined group to the extent that the ruling relates to that member and that member was identified in the private letter ruling request.
A private letter ruling is not binding on the Comptroller if:
- material facts were omitted or misstated in the request;
- the facts subsequently developed are materially different from the facts on which the ruling was based; or
- prospectively if:
- a Texas or federal court decision that the Comptroller determines affects the ruling's validity becomes final and non-appealable;
- there has been a change in the applicable laws, rules or Comptroller decisions; or
- the Comptroller has modified or revoked the private letter ruling.
Modification or Revocation
The Comptroller can modify or revoke a private letter ruling if the ruling is found to be in error or not in accordance with laws or current Comptroller policy. The Comptroller will not apply the modification or revocation retroactively with respect only to the particular issue and the person identified in the private letter ruling request.
Our office will mail a written notice of a modification or revocation to the taxpayer's address as it appears in Comptroller records. If there are no Comptroller records, the notice will be mailed to the contact information provided in the private letter ruling request.
If the modification or revocation is due to a change in state or federal law, a final decision of a court of law or a change in agency rule, the effective date of the modification or revocation is the date of the event requiring the modification or revocation.
If a ruling is modified or revoked due to a change in Comptroller policy that is not reflected in an agency rule, the ruling is effective until the date of the written notice sent to the requestor or person for whom the request was made.
Privacy and Publishing PLRs
Information provided to the Comptroller when requesting a general information letter or a private letter ruling is subject to the Public Information Act and controlling interpretations of the Attorney General's office and court decisions that apply to the Comptroller’s office.
Our office will publish all private letter rulings, redacted for privacy, on the State Tax Automated Research (STAR) system, including information regarding any modification or revocation of rulings.