Illinois DOR Issues General Information Letter on Exempt Property Purchased by Construction Contractors

The Illinois Department of Revenue (DOR) issued a general information letter regarding the taxability of solar installations in a school district by a third party. DOR held that tangible personal property purchased by construction contractors for contracts with entities that do not have an Exempt Identification Number is not exempt from retailers’ occupation tax and use tax, even if the property will be owned by the non-E-number entity upon incorporation. The exemption applies only if the construction contract is directly between the contractor and the E-number holder. [Il. Dep’t of Revenue, ST-25-0042-GIL, 08/01/25]

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