Letter Rulings

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Act 105, SLH 2011

Letter rulings on Act 105, SLH 2011
Number	Date	Title/Description
2013-02	April 3, 2013	Act 105, SLH 2011, 237-25 Ruling discussing whether a taxpayer’s gross proceeds are exempt under section 237-25 due to the grandfathering provisions of Act 105, Session Laws of Hawaii 2011.
2012-08	June 5, 2012	Act 105 SLH 2011, HRS 237-13(3)(B) Discussing whether a government contract qualifies for the grandfathering exception to the temporary suspension of certain general excise tax exemptions under section Act 105, Session Laws of Hawaii 2011.

Act 155, SLH 2010

Letter rulings on Act 155, SLH 2010
Number	Date	Title/Description
2010-16	August 3, 2010	Act 155, SLH 2010 Letter ruling discussing the application of Act 155, SLH 2010, to a federal instrumentality.

235-1

Letter rulings on 235-1
Number	Date	Title/Description
2021-01	July 26, 2021	HRS 235-1 Discussing whether a taxpayer will not be considered a resident of Hawaii even though taxpayer spent more than 200 days in this State, and for determination as to whether income earned is subject to Hawaii income tax.

235-2.3

Letter rulings on 235-2.3
Number	Date	Title/Description
2012-07	May 31, 2012	HRS 235-2.3 Discussing whether benefits received pursuant to section 701 of the Public Safety Officer’s Benefits Act of 1976 are deemed to be workmen’s compensation and therefore excludable from Hawaii adjusted gross income.

235-2.45

Letter rulings on 235-2.45
Number	Date	Title/Description
2010-08	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5, 235-2.45 Qualified high technology business comfort ruling for company whose qualified research is qualified research as defined under section 41(d) of the Internal Revenue Code and biotechnology. Includes a discussion relating to investment credit claim timing, credit allocations, and issues associated with investors that are insurance companies.

235-2.45(d)

Letter rulings on 235-2.45(d)
Number	Date	Title/Description
2009-06	October 9, 2009	HRS 235-110.9, 235-2.45(d) Qualified high technology business comfort ruling for a previously qualified company on whether a proposed method of allocating credits generated from investments made on or after May 1, 2009 complies with HRS § 235-2.45(d), as amended by Act 178 SLH 2009.

235-2.45(e)

Letter rulings on 235-2.45(e)
Number	Date	Title/Description
2010-09	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5; 235-2.45(e) Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software.

235-7(a)(13)

Letter rulings on 235-7(a)(13)
Number	Date	Title/Description
2010-17	August 4, 2010	HRS 235-7(a)(13) Letter ruling discussing the exclusion from income tax of gain realized from the sale of leased fee interests in condominium units to the condominium’s association of apartment owners.

235-7.3

Letter rulings on 235-7.3
Number	Date	Title/Description
2011-02	February 4, 2011	235-7.3 Letter ruling discussing the application of the income tax exclusion for royalties and other income under Section 235-7.3, HRS, to an actor receiving royalties or other income from performing arts products.
2010-34	December 30, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-33	December 13, 2010	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the design and development of computer software.
2010-30	November 23, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology and ocean science.
2010-24	October 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-22	October 6, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-19	September 10, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Increases the comfort ruling credit cap in a previously issued QHTB comfort ruling letter.
2010-13	July 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-11	April 28, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology.
2010-10	April 27, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-09	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5; 235-2.45(e) Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software.
2010-08	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5, 235-2.45 Qualified high technology business comfort ruling for company whose qualified research is qualified research as defined under section 41(d) of the Internal Revenue Code and biotechnology. Includes a discussion relating to investment credit claim timing, credit allocations, and issues associated with investors that are insurance companies.
2009-10	December 11, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology
2009-09	November 30, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is the creation of performing arts products.
2009-08	November 23, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business letter ruling providing an increase in the cap amount of investments that may rely upon conclusions set forth in a prior comfort ruling.

235-9.5

Letter rulings on 235-9.5
Number	Date	Title/Description
2010-34	December 30, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-33	December 13, 2010	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the design and development of computer software.
2010-30	November 23, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology and ocean science.
2010-24	October 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-22	October 6, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-19	September 10, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Increases the comfort ruling credit cap in a previously issued QHTB comfort ruling letter.
2010-13	July 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-11	April 28, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology.
2010-10	April 27, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-09	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5; 235-2.45(e) Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software.
2010-08	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5, 235-2.45 Qualified high technology business comfort ruling for company whose qualified research is qualified research as defined under section 41(d) of the Internal Revenue Code and biotechnology. Includes a discussion relating to investment credit claim timing, credit allocations, and issues associated with investors that are insurance companies.
2009-10	December 11, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology
2009-09	November 30, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is the creation of performing arts products.
2009-08	November 23, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business letter ruling providing an increase in the cap amount of investments that may rely upon conclusions set forth in a prior comfort ruling.
2009-05	September 15, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the development and design of certain computer software
2009-04	September 2, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and non-fossil fuel energy related technology
2009-03	August 31, 2009	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology
2009-02	August 28, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software
2009-01	June 29, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software

235-12.5

Letter rulings on 235-12.5
Number	Date	Title/Description
2018-01	September 12, 2018	HRS 235-12.5 Letter ruling discussing when a commercial solar energy system is deemed “installed and placed in service” for the purpose of the renewable energy technologies income tax credit.
2012-05	February 2, 2012	HRS 235-12.5 Letter ruling discussing three companies’ installations of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether the companies installed commercial systems for purposes of the renewable energy technologies income tax credit.
2012-03	January 9, 2012	HRS 235-12.5 Reaffirming, notwithstanding proposed changes to the project configuration and company ownership, a prior letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes as well as whether the company installed commercial systems.
2012-01	January 9, 2012	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2011-07	September 13, 2011	HRS 235-12.5 Determining that a taxpayer, in a situation where more than one renewable energy technology system is necessitated, has legitimate, nontax reasons for choosing the composition of those multiple systems.
2011-06	September 2, 2011	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2011-03	February 11, 2011	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2011-01	January 27, 2011	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2010-29	November 23, 2010	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2010-27	November 4, 2010	HRS 235-12.5 Letter ruling discussing a company’s installation of multiple renewable energy technology systems for nontax purposes, as well as a determination of whether a company has installed a commercial system for purposes of the renewable energy technologies income tax credit.
2010-25	October 15, 2010	HRS 235-12.5 Letter ruling discussing a nonresident individual’s claim for the renewable energy technologies income tax credit in refundable form.
2010-23	October 6, 2010	HRS 235-12.5 Letter ruling determining a “system” for purposes of the renewable energy technologies income tax credit.
2010-20	August 18, 2010	HRS 235-12.5 Letter ruling regarding the renewable energy technologies income tax credit and its application to multiple systems in the context of multiple single-family residential properties.
2010-05	March 25, 2010	HRS 235-12.5 Letter ruling regarding the application of the renewable energy technologies income tax credit in commercial applications, as well as defining the term “system” for purposes of the credit.

235-17

Letter rulings on 235-17
Number	Date	Title/Description
2010-18	Auguat 26, 2010	HRS 235-17 Application of TIR 2010-04 to separate motion picture production companies.

235-61

Letter rulings on 235-61
Number	Date	Title/Description
2009-07	November 10, 2009	HRS 235-61 Letter ruling regarding Hawaii income tax withholding obligations for crew members working on research vessels.

235-68

Letter Rulings on 235-68
Number	Date	Title/Description
2011-09	November 10, 2011	HRS 235-68 Letter ruling regarding the application of HARPTA to sales of real property located in Hawaii.

235-110.9

Letter rulings on 235-110.9
Number	Date	Title/Description
2010-34	December 30, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-33	December 13, 2010	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the design and development of computer software.
2010-30	November 23, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology and ocean science.
2010-24	October 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-22	October 6, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is performing arts products.
2010-19	September 10, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Increases the comfort ruling credit cap in a previously issued QHTB comfort ruling letter.
2010-15	August 2, 2010	HRS 235-110.9 Increases the comfort ruling credit cap in a previously issued QHTB comfort ruling letter.
2010-13	July 14, 2010	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-12	May 3, 2010	HRS 235-110.9 Letter discussing the allocation of high technology business investment tax credits generated from investments made before May 1, 2009.
2010-11	April 28, 2010	HRS 235-110.9; 235-7.3; 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology.
2010-10	April 27, 2010	HRS 235-110.9; 235-7.3; 235td valign=”top”-9.5 Qualified high technology business comfort ruling for company whose qualified research is performing arts products.
2010-09	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5; 235-2.45(e) Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software.
2010-08	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5, 235-2.45 Qualified high technology business comfort ruling for company whose qualified research is qualified research as defined under section 41(d) of the Internal Revenue Code and biotechnology. Includes a discussion relating to investment credit claim timing, credit allocations, and issues associated with investors that are insurance companies.
2009-10	December 11, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is biotechnology
2009-09	November 30, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is the creation of performing arts products.
2009-08	November 23, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business letter ruling providing an increase in the cap amount of investments that may rely upon conclusions set forth in a prior comfort ruling.
2009-06	October 9, 2009	HRS 235-110.9, 235-2.45(d) Qualified high technology business comfort ruling for a previously qualified company on whether a proposed method of allocating credits generated from investments made on or after May 1, 2009 complies with HRS § 235-2.45(d), as amended by Act 178 SLH 2009.
2009-05	September 15, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the development and design of certain computer software
2009-04	September 2, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and non-fossil fuel energy related technology
2009-03	August 31, 2009	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology
2009-02	August 28, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software
2009-01	June 29, 2009	HRS 235-110.9, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software

235-110.91

Letter rulings on 235-110.91
Number	Date	Title/Description
2010-33	December 13, 2010	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the design and development of computer software.
2010-09	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5; 235-2.45(e) Qualified high technology business comfort ruling for company whose qualified research is the development and design of certain computer software.
2010-08	April 16, 2010	HRS 235-110.9; 235-110.91; 235-7.3; 235-9.5, 235-2.45 Qualified high technology business comfort ruling for company whose qualified research is qualified research as defined under section 41(d) of the Internal Revenue Code and biotechnology. Includes a discussion relating to investment credit claim timing, credit allocations, and issues associated with investors that are insurance companies.
2009-05	September 15, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and the development and design of certain computer software
2009-04	September 2, 2009	HRS 235-110.9, 235-7.3, 235-9.5, 235-110-91 Qualified high technology business comfort ruling for a company whose qualified research is in research as defined under Internal Revenue Code section 41(d) and non-fossil fuel energy related technology
2009-03	August 31, 2009	HRS 235-110.9, 235-110.91, 235-7.3, 235-9.5 Qualified high technology business comfort ruling for a company whose qualified research is biotechnology

236E-5

Letter rulings on 236E-5
Number	Date	Title/Description
2019-01	September 4, 2019	HRS 236E-5 Letter Ruling Request for an Extension to Elect Portability for Estate Tax Purposes

237-4(a)

Letter rulings on 237-4(a)
Number	Date	Title/Description
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

237-4(a)(8)

Letter rulings on 237-4(a)(8)
Number	Date	Title/Description
2010-21	September 27, 2010	HRS 237-4(a)(8); 237-13.3 Letter ruling which discusses the application of the general excise tax wholesale rate to sales of leis to hotels.
2010-07	April 8, 2010	HRS 237-4(a)(8); 237-4(a)(10); 237-24.3(7) Letter ruling regarding the application of the general excise tax wholesale rate to sales of medical supplies.

237-4(a)(10)

Letter rulings on 237-4(a)(10)
Number	Date	Title/Description
2010-07	April 8, 2010	HRS 237-4(a)(8); 237-4(a)(10); 237-24.3(7) Letter ruling regarding the application of the general excise tax wholesale rate to sales of medical supplies.

237-4(a)(10)(i)

Letter rulings on 237-4(a)(10)(i)
Number	Date	Title/Description
2010-02	February 10, 2010	HRS 237-4(a)(10)(i); 237-7; 237-25 Letter ruling regarding the general excise tax exemption for sales of tangible personal property to the federal government where the purchase price includes a free ‘repair or replacement’ warranty.

237-7

Letter rulings on 237-7
Number	Date	Title/Description
2012-12	August 6, 2012	HRS 237-7, 237-29.53; HAR 18-237-8.6-03 Discussing whether income earned as an editor of a publication for an out-of-state organization is subject to General Excise Tax and whether income earned from the sale of freelance articles is subject to General Excise Tax.
2010-02	February 10, 2010	HRS 237-4(a)(10)(i); 237-7; 237-25 Letter ruling regarding the general excise tax exemption for sales of tangible personal property to the federal government where the purchase price includes a free ‘repair or replacement’ warranty.

237-8.6

Letter Rulings on 237-8.6
Number	Date	Title/Description
2012-11	July 17, 2012	HRS 237-8.6 Discussing whether the county surcharge is applicable to gross receipts obtained from transactions in which Taxpayer’s customers use or consume the service outside the Oahu taxation district.

237-9.3

Letter rulings on 237-9.3
Number	Date	Title/Description
2012-15	September 19, 2012	HRS 237-9.3; 237-23 Discussing whether a state of Hawaii licensed fraternal benefit society, exempt from General Excise Tax under section 432:2-503, HRS, must also comply with the requirements of sections 237-23 and 237-9.3, HRS, in order to be exempt from General Excise Tax.
2012-14	September 19, 2012	HRS 237-9.3; 237-23 Discussing whether a state of Hawaii licensed fraternal benefit society, exempt from General Excise Tax under section 432:2-503, HRS, must also comply with the requirements of sections 237-23 and 237-9.3, HRS, in order to be exempt from General Excise Tax.

237-13

Letter rulings on 237-13
Number	Date	Title/Description
2012-04	January 24, 2012	HRS 237-13; 237-24.3(8); 237D-1; 237D-2; 237D-3 Discussing the General Excise Tax and Transient Accommodations Tax obligations of a Taxpayer engaged in the rental of accommodations in rehabilitated military barracks located on a secure military installation in Hawaii.

237-13(1)(A)

Letter rulings on 237-13(1)(A)
Number	Date	Title/Description
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

237-13(2)(A)

Letter Rulings on 237-13(2)(A)
Number	Date	Title/Description
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

237-13(2)(B)

Letter rulings on 237-13(2)(B)
Number	Date	Title/Description
2012-10	July 10, 2012	HRS 237-13(2)(B); HAR 237-13-02.01; HAR 237-13-8.6-02 Discussing whether an out-of-state retailer is subject to general excise tax on gross income from sales of tangible personal property sold to persons in Hawaii, where that seller has an affiliate company which has brick-and-mortar retail locations in Hawaii.

237-13(3)(B)

Letter rulings on 237-13(3)(B)
Number	Date	Title/Description
2012-08	June 5, 2012	Act 105 SLH 2011, HRS 237-13(3)(B) Discussing whether a government contract qualifies for the grandfathering exception to the temporary suspension of certain general excise tax exemptions under section Act 105, Session Laws of Hawaii 2011.

237-13(6)(A)

Letter rulings on 237-13(6)(A)
Number	Date	Title/Description
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

237-13.3

Letter rulings on 237-13.3
Number	Date	Title/Description
2010-21	September 27, 2010	HRS 237-4(a)(8); 237-13.3 Letter ruling which discusses the application of the general excise tax wholesale rate to sales of leis to hotels.

237-16(A)

Letter rulings on 237-16(A)
Number	Date	Title/Description
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

237-17

Letter rulings on 237-17
Number	Date	Title/Description
2010-14	July 29, 2010	HRS 237-24(13); 237-17 Letter ruling discussing the general excise tax rate and exemptions for corporations all of whose outstanding shares are owned by individuals who are blind, deaf, or totally disabled.

237-20

Letter rulings on 237-20
Number	Date	Title/Description
2011-12	December 9, 2011	HRS 237-20 Letter ruling discussing the reimbursement exemption under section 237-20.
2010-06	March 23, 2010	HRS 237-20 Letter ruling regarding general excise tax treatment of amounts withheld by manager of an apartment rental program.

237-23

Letter rulings on 237-23
Number	Date	Title/Description
2012-15	September 19, 2012	HRS 237-9.3; 237-23 Discussing whether a state of Hawaii licensed fraternal benefit society, exempt from General Excise Tax under section 432:2-503, HRS, must also comply with the requirements of sections 237-23 and 237-9.3, HRS, in order to be exempt from General Excise Tax.
2012-14	September 19, 2012	HRS 237-9.3; 237-23 Discussing whether a state of Hawaii licensed fraternal benefit society, exempt from General Excise Tax under section 432:2-503, HRS, must also comply with the requirements of sections 237-23 and 237-9.3, HRS, in order to be exempt from General Excise Tax.

237-23(a)(4)

Letter rulings on 237-23(a)(4)
Number	Date	Title/Description
2010-26	October 19, 2010	HRS 237-23(b)(3), 237-23(a)(4) Application of the general excise tax on the sale of audio tours by a nonprofit organization.

237-23(b)(3)

Letter rulings on 237-23(b)(3)
Number	Date	Title/Description
2010-26	October 19, 2010	HRS 237-23(b)(3), 237-23(a)(4) Application of the general excise tax on the sale of audio tours by a nonprofit organization.

237-23.5

Letter rulings on 237-23.5
Number	Date	Title/Description
2012-13	September 19, 2012	HRS 237-23.5; 237-24.75 Discussing whether the professional employment organization exemption from General Excise Tax applies to a company and its subsidiary which co-employ employees and whether the related entities exemption from General Excise Tax applies to fees received by a company in exchange for the performance of administrative services for its subsidiary.

237-24(13)

Letter rulings on 237-24(13)
Number	Date	Title/Description
2010-14	July 29, 2010	HRS 237-24(13); 237-17 Letter ruling discussing the general excise tax rate and exemptions for corporations all of whose outstanding shares are owned by individuals who are blind, deaf, or totally disabled.

237-24.3

Letter rulings on 237-24.3
Number	Date	Title/Description
2012-09	May 30, 2012	HRS 237-24.3; 237-29.5 Application of General Excise Tax to income received from sales of agricultural, meat, or fish products sold to airlines for consumption out-of-state by airlines’ passengers.

237-24.3(7)

Letter Rulings on 237-24.3(7)
Number	Date	Title/Description
2010-07	April 8, 2010	HRS 237-4(a)(8); 237-4(a)(10); 237-24.3(7) Letter ruling regarding the application of the general excise tax wholesale rate to sales of medical supplies.

237-24.3(8)

Letter Rulings on 237-24.3(8)
Number	Date	Title/Description
2012-04	January 24, 2012	HRS 237-13; 237-24.3(8); 237D-1; 237D-2; 237D-3 Discussing the General Excise Tax and Transient Accommodations Tax obligations of a Taxpayer engaged in the rental of accommodations in rehabilitated military barracks located on a secure military installation in Hawaii.

237-24.9

Letter rulings on 237-24.9
Number	Date	Title/Description
2010-01	January 22, 2010	HRS 237-24.9; 238-1(8) Letter ruling regarding the application of the use tax to a jet engine imported into the State as a spare part.

237-24.75

Letter rulings on 237-24.75
Number	Date	Title/Description
2012-13	September 19, 2012	HRS 237-23.5; 237-24.75 Discussing whether the professional employment organization exemption from General Excise Tax applies to a company and its subsidiary which co-employ employees and whether the related entities exemption from General Excise Tax applies to fees received by a company in exchange for the performance of administrative services for its subsidiary.
2010-31	December 1, 2010	HRS 237-24.75, 373K-1 Letter ruling discussing the application of the Professional Employment Organization (PEO) general excise tax exemption to a company providing PEO services to a group of related companies and a third party.

237-25

Letter rulings on 237-25
Number	Date	Title/Description
2013-12	April 3, 2013	Act 105, SLH 2011, 237-25 Ruling discussing whether a taxpayer’s gross proceeds are exempt under section 237-25 due to the grandfathering provisions of Act 105, Session Laws of Hawaii 2011.
2011-11	December 7, 2011	237-25, 237-29.5, 237-29.53, 238-2, 238-2.3 HRS Letter ruling regarding the general excise tax exemption for sales of tangible personal property to the federal government in Hawaii.
2010-02	February 10, 2010	HRS 237-4(a)(10)(i); 237-7; 237-25 Letter ruling regarding the general excise tax exemption for sales of tangible personal property to the federal government where the purchase price includes a free ‘repair or replacement’ warranty.

237-26

Letter rulings on 237-26
Number	Date	Title/Description
2012-02	January 6, 2012	HRS 237-26 Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.
2011-10	December 7, 2011	HRS 237-26 Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.
2011-08	August 30, 2011	HRS 237-26 Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.
2011-04	May 23, 2011	HRS 237-26 Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.
2010-28	November 16, 2010	HRS 237-26; 238-3(j) Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.

237-28.1

Letter rulings on 237-28.1
Number	Date	Title/Description
2010-03	March 3, 2010	HRS 237-28.1 Letter ruling regarding the general excise tax exemption for proceeds received from ship repair of federally owned vessels.

237-29.5

Letter rulings on 237-29.5
Number	Date	Title/Description
2012-09	May 30, 2012	HRS 237-24.3; 237-29.5 Application of General Excise Tax to income received from sales of agricultural, meat, or fish products sold to airlines for consumption out-of-state by airlines’ passengers.
2012-06	March 23, 2012	HRS 237-29.5; 237-29.53 Letter ruling discussing whether general excise tax must be paid on the sale of software developed and then licensed and/or sold to a related company.
2011-11	December 7, 2011	HRS 237-25, 237-29.5, 237-29.53, 238-2, 238-2.3 Letter ruling regarding the general excise tax exemption for services exported to a federal government customer located outside Hawaii.

237-29.53

Letter rulings on 237-29.53
Number	Date	Title/Description
2013-01	January 16, 2013	HRS 237-29.53 Discussing whether certain gross receipts are exempt from general excise tax under HRS §237-29.53
2012-12	August 6, 2012	HRS 237-7, 237-29.53; HAR 18-237-8.6-03 Discussing whether income earned as an editor of a publication for an out-of-state organization is subject to General Excise Tax and whether income earned from the sale of freelance articles is subject to General Excise Tax.
2012-06	March 23, 2012	HRS 237-29.5; 237-29.53 Letter ruling discussing whether general excise tax must be paid on the sale of software developed and then licensed and/or sold to a related company.
2011-11	December 7, 2011	HRS 237-25, 237-29.5, 237-29.53, 238-2, 238-2.3 Letter ruling regarding the general excise tax exemption for services exported to a federal government customer located outside Hawaii.

237D-1

Letter rulings on 237D-1
Number	Date	Title/Description
2012-04	January 24, 2012	HRS 237-13; 237-24.3(8); 237D-1; 237D-2; 237D-3 Discussing the General Excise Tax and Transient Accommodations Tax obligations of a Taxpayer engaged in the rental of accommodations in rehabilitated military barracks located on a secure military installation in Hawaii.

237D-2

Letter rulings on 237D-2
Number	Date	Title/Description
2012-04	January 24, 2012	HRS 237-13; 237-24.3(8); 237D-1; 237D-2; 237D-3 Discussing the General Excise Tax and Transient Accommodations Tax obligations of a Taxpayer engaged in the rental of accommodations in rehabilitated military barracks located on a secure military installation in Hawaii.

237D-3

Letter rulings on 237D-3
Number	Date	Title/Description
2012-04	January 24, 2012	HRS 237-13; 237-24.3(8); 237D-1; 237D-2; 237D-3 Discussing the General Excise Tax and Transient Accommodations Tax obligations of a Taxpayer engaged in the rental of accommodations in rehabilitated military barracks located on a secure military installation in Hawaii.

238-1(6)

Letter rulings on 238-1(6)
Number	Date	Title/Description
2010-32	December 2, 2010	HRS 238-1(6) Letter ruling discussing the application of the use tax to a portfolio of commercial aircraft used in interstate air transportation.

238-1(8)

Letter rulings on 238-1(8)
Number	Date	Title/Description
2010-01	January 22, 2010	HRS 237-24.9; 238-1(8) Letter ruling regarding the application of the use tax to a jet engine imported into the State as a spare part.

238-2

Letter rulings on 238-2
Number	Date	Title/Description
2011-11	December 7, 2011	237-25, 237-29.5, 237-29.53, 238-2, 238-2.3 Letter ruling regarding the imposition of use tax on the importation of tangible personal property for sale to the federal government in Hawaii.
2010-04	March 4, 2010	HRS 237-13(2)(A); 237-4(a); 237-13(1)(A); 237-13(6)(A); 237-16(A); 238-2 Letter ruling regarding the application of the general excise tax on the sale of tangible personal property by an out-of-state seller.

238-2.3

Letter rulings on 238-2.3
Number	Date	Title/Description
2011-11	December 7, 2011	237-25, 237-29.5, 237-29.53, 238-2, 238-2.3 Letter ruling regarding the imposition of use tax on imported services sold to the federal government at locations in Hawaii and outside of Hawaii.

238-3(j)

Letter rulings on 238-3(j)
Number	Date	Title/Description
2010-28	November 16, 2010	HRS 237-26; 238-3(j) Letter ruling discussing the proper treatment of gross proceeds derived from the performance of scientific work under contracts entered into with the United States.

251-2

Letter rulings on 251-2
Number	Date	Title/Description
2011-05	May 23, 2011	HRS 251-2 Letter ruling regarding the imposition of rental motor vehicle surcharge tax upon certain types of motor vehicles.

373K-1

Letter rulings on 373K-1
Number	Date	Title/Description
2010-31	December 1, 2010	HRS 237-24.75, 373K-1 Letter ruling discussing the application of the Professional Employment Organization (PEO) general excise tax exemption to a company providing PEO services to a group of related companies and a third party.

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