S.F. No. 728 Summary

• Establishes a private letter ruling program by January 1, 2024, allowing the Minnesota Department of Revenue commissioner to issue rulings explaining how state tax law applies to specific taxpayer transactions or arrangements.

• Commissioner may set application procedures, require supporting documentation, and establish a fee schedule to recover actual costs of preparing rulings, with fees varying by complexity and deposited into the Revenue Department service and recovery fund.

• Rulings are binding on the commissioner if no material facts were misstated, facts don't materially differ from those provided, applicable law hasn't changed, and the taxpayer acted in good faith; rulings have no precedential effect for other taxpayers.

• Commissioner must publish all rulings on the department website organized by tax type in searchable format with taxpayer identifying information redacted.

• Commissioner must report biannually to the legislature by January 31 of odd-numbered years on application numbers, rulings issued, refunded fees, tax types, taxpayer characteristics, and other relevant program information; first report due January 31, 2026.