Tax Type
Individual Income Tax
Description
Foreign source income
Topic
Subtractions and Exclusions
Date Issued
09-21-1987
September 21, 1987
Re: Virginia Code §58.1-1821 Application
Individual Income Tax
Dear ******************
This is in reply to your letter of August 26, 1986 in which you disagreed with the department's determination as set forth in my letter of July 15, 1986. I apologize for the delay in responding to your letter and I hope that the delay has not caused you or your client any inconvenience.
While the department understands your position, we continue to feel that the policy set forth in the Virginia Individual Income Tax Regulations and my letter of July 15, 1986 is consistent with the applicable statute and accurately reflects the intent of the legislature in enacting the Virginia foreign source income subtraction (1981 Acts of Assembly, Chapter 402, Senate Bill 641). The rationale behind this policy and the department's analysis of the legislative history of the provision is set forth in the attachment to my July 15, 1986 letter.
Therefore, based upon the department's policy as set forth in Virginia Regulation 630-2-302, I cannot find basis for relief of the assessment issued to your client.
Sincerely,
W. H. Forst
Tax Commissioner
Rulings of the Tax Commissioner