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Miscellaneous Taxes & Fees Letter Rulings


Private Letter Rulings & General Information Letters

Businesses and individuals can request a general information letter or private letter ruling on any tax administered by the department. General information letters are general discussions of tax issues that are not specifically addressed in other department publication, such as FYIs, rules and regulations, or form instructions. General Information Letters are general statements of department understanding and cannot be relied upon as binding guidance. Private letter rulings are specific determinations of the tax consequences of a proposed or completed transaction. Unlike general information letters, private letter rulings are binding on the department and, therefore, provide taxpayers with greater certainty for their business and personal taxes. However, private letter rulings can only be relied upon by the party to whom the ruling is issued. Private letter rulings cannot be relied upon by any taxpayer other than the taxpayer to whom the ruling is made. For more information about general information letters and private letter rulings including fee amounts and how to submit a request, please see department regulation 24-35-103.5.



Affiliation of Retail Marijuana Business Licensees for the Purpose of Determining Excise Tax - Published November 13, 2023

Common ownership between marijuana business licensees is not a requirement for affiliation. Because Company X has control via contracts over both Company A and multiple dispensaries, Company A is under common control with the dispensaries. Company A and the dispensaries are affiliated marijuana licensees because they are controlled by the same interest.


Vehicle Sharing Transactions

Vehicle sharing platform operator must collect sales taxes and daily rental fees from drivers on vehicle sharing transactions.


Transferable Tax Credit Program

This letter addresses the transferable income tax credits in section 24-46-104.3, and specifically how the transfer of eligible Enterprise Zone credits are treated by the Department.


Paint Stewardship Fee

The fee that is required pursuant to § 25-17-404(2)(j), C.R.S. is included in the calculation of sales tax when purchasing architectural paint.