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2026 Sales Tax Letter Rulings

General Information Letters

Ruling Date Subject Synopsis
ST-26-0001-GIL
01/09/2026 Manufactured Homes Mobile homes and manufactured homes in mobile home parks must be assessed and taxed as chattel. See 35 ILCS 517/5. The first sale by the mobile home park owner of the manufactured home located in the mobile home park to a purchaser is reported with Retailers’ Occupation Tax paid on Form ST-556, Sales Tax Transaction Return. Each subsequent sale of the manufactured home by the mobile home park owner to another purchaser must also be reported with tax paid on Form ST-556. (This is a GIL).
ST-26-0002-GIL 01/14/2026 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. Leases subject to retailers’ occupation taxes are sourced to either the primary property location or the same as other retail sales. See 35 ILCS 120/2-12(5.5) as amended by Article 75 of Public Act 103-592. (This is a GIL).
ST-26-0003-GIL 01/22/2026 Leasing Effective January 1, 2025, persons engaged in the business of leasing tangible personal property at retail (“lessors”) in Illinois are subject to State and local retailers’ occupation tax on the gross receipts from leases of tangible personal property made in the course of business. See 35 ILCS 120/2 as amended by Article 75 of Public Act 103-592. Leases subject to retailers’ occupation taxes are sourced to either the primary property location or the same as other retail sales. See 35 ILCS 120/2-12(5.5) as amended by Article 75 of Public Act 103-592. (This is a GIL).
ST-26-0004-GIL 01/23/2026 Parking Excise Tax Separately stated charges that are not related to or incidental to obtaining the use or privilege of using a parking space in a parking area or garage would not be subject to the tax. 35 ILCS 525; 86 Ill. Adm. Code 195. (This is a GIL).
ST-26-0005-GIL 01/27/2026 Motor Vehicles Recreational vehicles and cargo trailers meeting certain requirements that are sold in Illinois to Indiana residents are eligible for the drive-away permit exemption of the Retailers’ Occupation Tax. (This is a GIL).
ST-26-0006-GIL 02/24/2026 Sales of Service Sales of service, where tangible personal property is transferred incident to the service, are not exempt from taxation. Servicepersons must calculate their tax liability using one of the four methods prescribed in 86 Ill. Adm. Code Part 140. (This is a GIL).
ST-26-0007-GIL 03/24/2026 Medical Appliances A medical appliance is an item that is used to directly substitute for a malfunctioning part of the human body. See 86 Ill. Adm. Code 130.131(e). (This is a GIL).
ST-26-0008-GIL 03/11/2026 Motor Vechicles If the seller is making a goodwill repair at the direction of a manufacturer, and where a manufacturer provides tangible personal property to the seller for the goodwill repair, a service situation exists in which the person making the repairs is the serviceperson and the seller is the service customer. See 86 Ill. Adm. Code 140.141(c)(3)(B). (This is a GIL).
ST-26-0009-GIL 03/26/2026 Computer Software Computer software provided via a cloud-based delivery system, where the software is never downloaded onto a client's computer and is only accessed remotely, is not subject to tax. See 86 Ill. Adm. Code 130.1935(a)(3). Voice Over Internet Protocol ("VoIP") is telecommunications subject to tax within the meaning of "Telecommunications" and "Gross Charges" pursuant to The Telecommunications Excise Tax. 86 Ill. Adm. Code 495.100. (This is a GIL).
ST-26-0010-GIL 04/07/2026 Leasing This letter discusses the application of taxes on lease receipts imposed by a home rule unit of local government. (This is a GIL).
ST-26-0011-GIL 04/10/2026 Retailers' Occupation Tax When tangible personal property is sold at retail along with related service charges, the related service charges are part of the gross receipts subject to the Retailers' occupation Tax if an "inseparable link" exists between the tangible personal property and the service charges. See 86 Ill. Adm. Code 130.415. (This is a GIL.)
ST-26-0013-GIL 04/28/2026 Cannabis Purchaser Excise Tax Cannabis purchaser excise tax is not part of the seller's gross receipts subject to tax. (This is a GIL.)
ST-26-0014-GIL 04/28/2026 Retailres' Occupation Tax Deal-of-the-Day vouchers are intangible personal property. Therefore, sales of Deal-of-the-Day vouchers are not subject to sales tax. See 86 Ill. Adm. Code 130.2125. (This is a GIL.)
ST-26-0015-GIL 05/01/2026 Books and Records Retailers must maintain all records that are necessary to determine the correct tax liability under the Retailers’ Occupation Tax Act including documentation for exempt and other non-taxable receipts, and those records must be made available to the Department upon request. See 86 Ill. Adm. Code 130.805. (This is a GIL).
ST-26-0016-GIL 05/05/2026 Gross Receipts Gross receipts include all the consideration actually received by the seller, which includes late charges and penalties for late payment. 86 Ill. Adm. Code 130.420. (This is a GIL).
ST-26-0017-GIL 05/06/2026 Leasing If the true object of the transaction is the service and tangible personal property is transferred by lease incident to the sale of service, the transfer of tangible personal property by lease is subject to the Service Occupation Tax Act. See 86 Ill. Adm. Code 130.102. (This is a GIL).
ST-26-0018-GIL 05/08/2026 Service Occupation Tax Generally, a provider of medical services is considered engaged in the business of making sales of services. As a serviceperson, the Service Occupation Tax is imposed upon all tangible personal property transferred as an incident to the sale of such service. Prescription and non-prescription medicines, drugs, and medical appliances are taxed at a reduced State rate of 1%, plus applicable local service taxes based on the location of the sale of the service. See 86 Ill. Adm. Code 140.126. (This is a GIL).

Private Letter Rulings

There are no 2026 Private Letter Rulings available at this time. New rulings will be posted here as they become available.