The SCDOR issues advisory opinions to provide guidance concerning the application of laws administered by the Department.
The SCDOR's Tax Policy Services Division currently issues four types of advisory opinions: Revenue Ruling (RR), Revenue Procedure (RP), Private Letter Ruling (PLR), and Information Letter (IL). Other advisory opinion types have been issued in the past.
The procedures for issuing advisory opinions, including the definition of each type, are outlined in Revenue Procedure 09-3.
- Advisory opinions remain in effect unless superseded or modified by a change in statute, regulation, court decision, or another SCDOR advisory opinion.
- Some are published as drafts for public review and comment before they are finalized.
- Once issued, advisory opinions are numbered sequentially, with the first two digits reflecting the publication year.
A Citator is issued quarterly and identifies the effect that new advisory opinions have on previous ones. The Citator does not include the effect that new laws, regulations, or court decisions have on previous advisory opinions.