SC Department of Revenue
Department Advisory Opinion Home Page



The Policy Section recommends Advisory Opinions to the Director for approval as set forth in SC Revenue Procedure #09-3. The types of advisory opinions are referred to as

    1. Revenue Rulings (Final and Temporary),
    2. Revenue Procedures (Final and Temporary), and
    3. Private Letter Rulings, and
    4. Information Letters

The purposes of advisory opinions include providing guidance to the general public and employees concerning the Department's opinion on the application of laws administered by the Department. These opinions are not binding on the public.

CAUTION: Our website contains advisory opinions and informational bulletins issued by the Department from 1987 to present. Many of these opinions have been modified, superseded, or are obsolete. The Department issues an Information Letter (a Citator) quarterly that identifies the effect new advisory opinions have on those previously published to the best of our knowledge. This Citator; however, does not include the effect new laws, regulations, or court decisions have on previously issued advisory opinions.

As part of the implementation of these purposes, the Department's website includes the following information on advisory opinions:

  • An Advisory Opinion E-Mail Subscription Service to allow the public to automatically receive draft, temporary, and final advisory opinions via e-mail.

  • An Alphabetical Index of Advisory Opinions (Temporary and Final)

  • A Calendar Year Index of Advisory Opinions (Temporary and Final)  (This index only contains advisory opinions issued on or after January 1, 2003) 

  • An Advisory Opinion Calendar where interested parties may track the progress of draft and temporary Revenue Rulings and Revenue Procedures. This includes information and deadlines on how to provide comments about and suggest alternatives to draft opinions. Upon issuance, the final advisory opinion will be listed here temporarily and will be indexed by topic.

  • An Information Guide briefly explaining the procedure for requesting an advisory opinion.

The Policy Section also publishes several Tax Manuals to provide businesses, Department of Revenue employees and tax professionals a central source of information concerning specific taxes.

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