Connecticut State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Connecticut, with full citations and the original source on every page.
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Did sales and use tax apply to greens fees or charges for golf, tennis, and swimming lessons?
No under this historical ruling. The health and athletic club services tax did not apply to greens fees or charges for golf, tennis, and swimming lessons. DRS says AN 95(3) obsoleted the ruling.
Were health and athletic club service fees charged by a charitable nonprofit organization subject to sales and use tax?
No under this historical ruling. Charges or fees for health and athletic club services provided by a charitable nonprofit organization were not subject to sales and use tax. DRS says AN 95(3) obsolete…
Which vending-machine foods at schools and colleges were exempt, and which remained taxable?
Food such as cookies, cakes, pastries, chips, milk, and coffee sold from vending machines in student cafeterias, student-union areas, and dormitory hallways was exempt under the educational food provi…
Were continuous thickness gauges mounted on production lines exempt manufacturing or quality-control machinery?
Yes on the ruling's narrow facts. Gauges mounted on rolling mills or processing lines, required to produce the finished product, and measuring continuously were exempt as machinery used directly in ma…
When were plumbing, HVAC, appliance installation, and repair labor taxable for owner-occupied homes and business property?
Installation labor was nontaxable at new construction and qualifying owner-occupied one- to three-family homes but taxable on existing commercial, industrial, or income-producing property. Repairs to …
Was the first finish-out of two never-finished, never-occupied floors taxable as renovation work?
No under this historical ruling. The first finish-out of floors never finished or occupied was nontaxable new construction. But any prior use of the unfinished space, including storage other than buil…
Were gross receipts from auditing residential or commercial mortgages subject to Connecticut sales and use tax?
No under this ruling. Connecticut DRS stated that the total gross receipts from a service auditing residential or commercial mortgages were not subject to sales and use tax.
Were a youth league's sales of pizza slices, hot dogs, candy bars, or soda for $5 or less exempt when the proceeds supported its youth activities?
Yes under this historical ruling. The listed items were exempt when sold for $5 or less and the proceeds were used exclusively for the youth activities the league sponsored and supported. The league s…
Was grinding existing pavement and reusing it as the base for a new parking lot taxable when no new materials were added?
No under this historical ruling. Recycling the pavement into the base of a new parking lot, without adding new materials during recycling, was treated as nontaxable new construction. DRS states that A…
Were total receipts for media-advertising services, including placement fees and development charges, subject to sales and use tax?
No under this historical ruling. Total receipts for advertising services related to television, radio, newspaper, or periodical advertising were not taxable, including placement fees and development c…
Were subterranean core sampling and test-hole drilling subject to sales and use tax?
Core sampling for engineers' predesign analysis was not taxable. Test-hole drilling was also nontaxable for new construction and existing owner-occupied one-, two-, or three-family residential propert…
Which furniture installation and delivery charges were taxable when furniture and movable office partitions were sold?
The furniture sale was taxable, but a separately stated installation charge for unpacking, arranging, and connecting removable panels was not. Delivery before title passed, including moving furniture …
Could a plumbing contractor act as a retailer, issue resale certificates for parts, and charge tax to customers?
Yes if the contractor qualified and was registered as a retailer of plumbing supplies, materials, or parts. Although contractors generally consume their materials and pay tax when buying them, a contr…
When did a sale to a federal agency qualify for Connecticut's governmental sales and use tax exemption?
The retailer had to bill the federal agency directly, receive payment directly from it, and obtain a completed exemption certificate for each sale. Billing an employee who paid personally did not qual…
How were a music manager's band-booking fees and client payments to the bands taxed?
Under this revoked ruling, Company X's booking fees were taxable employment-agency fees whether paid by clients or bands, while direct client payments to independent bands were not. If the musicians w…
Were greens fees, golf lessons, and tennis lessons, clinics, or tournaments at public and private clubs taxable?
No under this historical ruling. Greens fees and golf lessons, plus tennis lessons, clinics, and tournaments, were not taxable at either public or private clubs. DRS marks the ruling not current and o…
Which vending-machine sales at Connecticut state community and technical colleges were exempt?
Cookies, cakes, pastries, chips, milk, and coffee sold from machines in student cafeterias, student-union areas, and dormitory hallways were exempt under this historical ruling. Candy and carbonated b…
Were Company X's MRI and lithotripsy agreements equipment leases, and could it acquire the equipment for resale?
No. Because Company X retained substantial control over access, maintenance, operation, personnel, and insurance, it provided a service rather than leasing equipment. It could serve qualifying nonprof…
Were Company X's tour receipts taxable, and how were its purchases used to provide the tours treated?
The tour receipts were not subject to sales and use tax under this historical ruling. Company X was the final consumer of purchases used to perform the tours and had to pay applicable sales tax and/or…
Were X's broad real-estate development consulting services taxable as architectural, building-engineering, or commercial-property services?
No under this historical ruling. The described feasibility, market, financing, site, permitting, planning, design-coordination, marketing, construction-management, and tenant work was not taxable arch…
Were lobbying services performed by an employee for the employee's association employer taxable?
No under this historical ruling. Although lobbyist services became taxable on July 1, 1989, services an employee rendered for the employer were outside the tax. DRS said the apparent association emplo…
Were consulting services provided to a Connecticut public school subject to sales and use tax?
No under this ruling. Connecticut DRS stated that consulting services provided to a public school were exempt from sales and use tax under Conn. Gen. Stat. § 12-412(1).
Were asbestos-removal services and the tangible property used to perform them subject to sales and use tax?
Under this historical ruling, asbestos-removal services were excluded as voluntary hazardous-waste containment or removal. Tangible personal property bought to perform those services remained taxable.…
Which engineering, survey, feasibility, design, and permitting services for marina development were taxable?
Under this historical ruling, bathymetric and hydrographic surveys were taxable land surveying, and building-engineering or building-design portions were taxable. Listed environmental, testing, market…
Were asbestos site assessment, management analysis, removal planning, and abatement oversight taxable real-property services?
No under this historical ruling. The described asbestos assessment, removal-or-management analysis, plans, specifications, and abatement oversight were excluded as voluntary hazardous-waste containmen…
Was asbestos removal excluded from Connecticut sales and use tax as a hazardous-waste service?
Yes under this historical ruling. DRS treated asbestos removal as an excluded service for voluntarily containing or removing hazardous waste. DRS marks the information not current and says Special Not…
Which fabrication, installation, component-part, fixture, and repair charges were taxable under Connecticut Ruling 89-237?
Fabricated brackets, supplemental production-machinery parts, fixtures, and tangible-personal-property repairs were taxable on their full receipts, including labor and materials. Bracket installation …
Were aircraft charter receipts, aircraft-sale brokerage fees, and aircraft-storage rentals subject to Connecticut sales and use tax?
Charter receipts were taxable when a certificated carrier used in Connecticut an aircraft bought and held for resale, and brokerage fees were taxable for Connecticut aircraft sales. Aircraft-storage r…
Were services that reviewed and minimized clients' property tax assessments subject to Connecticut sales and use tax?
No under this historical ruling. DRS said X Company's service of reviewing and minimizing property tax assessments imposed on its clients was not subject to sales and use tax.
Were qualifying animal feed sales exempt, and were farmers exempt from repair-labor charges, under Connecticut Ruling 89-233?
Qualifying feed for livestock, rabbits, and poultry ordinarily used as human food was exempt without an exemption certificate. Farmers were not exempt from labor charges for repairing tangible persona…
Were total receipts from landscape, horticultural, and tree-removal services subject to Connecticut sales and use tax?
Yes under this historical ruling. Total gross receipts from landscape and horticultural services were taxable, and tree removal counted as a horticultural service. DRS marks the information not curren…
Which asbestos-removal, relocation, restoration, and renovation services were excluded from Connecticut sales tax?
Actual asbestos removal, containment, and disposal were excluded, as were directly related relocation and comparable-material restoration services. Renovations that enhanced or improved the area were …
Did X Foundation owe Connecticut sales tax on utility services purchased for its headquarters, including utilities associated with leased space?
No under this historical ruling. DRS said no sales tax was due on utility services purchased by X Foundation, whose property, income, obligations, and activities were exempt under Conn. Gen. Stat. § 1…
Were environmental engineering services taxable, and how did Connecticut treat building design included with those services?
Environmental engineering services were not taxable under this historical ruling, but designing a building to house a facility such as a water-treatment plant was taxable and had to be separately stat…
Were land-use planning, development-team coordination, and regulatory-process administration services subject to Connecticut sales and use tax?
No under this historical ruling. DRS did not classify X Company's services as taxable architectural or building-design, business-consulting or public-relations, or governmental lobbying or consulting …
How were manufacturer warranties, extended warranties, repair parts and services, and mixed maintenance contracts taxed under Connecticut Ruling 89-152?
Manufacturer-warranty repairs and parts were nontaxable. Extended-warranty repairs and parts were taxable, though the contract sale itself was not; no-charge parts triggered use tax, no-charge service…
Was photoengraving a manufacturing production process that qualified its machinery for Connecticut's sales-tax exemption?
No under this historical ruling. DRS classified photoengraving as processing, not manufacturing, because it did not substantially change personal property's form, composition, or character. The machin…
Were fire-scene analysis services performed for insurance companies subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the described fire-scene analyst services—determining cause, insured involvement, documenting for possible subrogation, and reporting findings—were not taxabl…
Was insurance appraisal work subject to Connecticut sales and use tax under Ruling 89-219?
No under this historical ruling. DRS said insurance appraisal work was not subject to sales and use tax, but it marks the information not current and says Ruling 94-10 superseded the ruling.
Were X-ray or chemical inspection services taxable when performed on real property or tangible personal property?
Inspections of industrial, commercial, or income-producing real property were taxable except for new construction, while inspections of tangible personal property were not taxable. DRS marks the guida…
Which water- and sewer-plant engineering and building-design services were taxable under Connecticut Ruling 89-214?
General engineering was not taxable, but design work for a permanent building housing process facilities was taxable. Subcontracted building design could be bought for resale, while easily disassemble…
Was creating trade-show exhibits a manufacturing production process for Connecticut sales and use tax purposes?
No under this historical ruling. DRS said creating trade-show exhibits was not a manufacturing production process and instead was governed by the contractor regulations in Conn. Agencies Regs. § 12-42…
Which landscape-planning services were nontaxable, and was landscape architecture taxable, under Connecticut Ruling 89-212?
Site assessment, environmental-impact studies, schematic concepts, site planning, plan review, rezoning requests, and wetlands approval were not taxable. Landscape architecture was taxable as landscap…
Did prepress computers and peripheral equipment qualify for Connecticut's manufacturing machinery exemption?
No under this historical ruling. DRS said prepress production machinery was not used directly in manufacturing a finished product for sale and therefore did not qualify under Conn. Gen. Stat. § 12-412…
Did Company X have to collect sales tax on management services provided to partnerships owning Connecticut housing projects?
Yes under this historical ruling. The services were taxable, the low-income nonprofit housing exemption covered tangible property rather than services, and the partnerships had not shown qualifying no…
Which energy, power, environmental, and industrial engineering design services were taxable under Connecticut Ruling 89-206?
Listed energy, power, environmental, water-resource, and pulp-and-paper engineering was not taxable, but building engineering, building planning or design, building programs, and interior design were …
Were an entertainment agency's fees for booking independent bands at Connecticut locations subject to sales and use tax?
Yes under this revoked ruling. X Company operated as an employment agency and had to tax its band-booking fees whether charged to the client or band. Payments made directly to bands by third-party cli…
When were water-pump and water-purification installation or repair charges taxable under Connecticut Ruling 89-204?
Repairs were taxable on parts and labor. Installation in new construction or qualifying owner-occupied one- to three-family residential property, including full-system replacement, was not taxable. DR…
Were process-engineering services for industrial environmental problems subject to Connecticut sales and use tax?
No under this historical ruling. DRS said X Corporation's process-engineering services, including wastewater treatment and hazardous-waste management for industrial clients, were not taxable as buildi…
Did a residence with an attached business office qualify for Connecticut's residential electricity exemption?
Yes under this historical ruling if at least 51% of the entire building, including the residence and office, was occupied for residential dwelling purposes. DRS says Policy Statement 94(3) superseded …
When did electricity sold to a job shop qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate finished products for sale and at least 75% of all electricity consumed at the location, building, or premises was used for f…
When did electricity sold to an optical-lens fabricator qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate optical lenses for sale and at least 75% of all electricity consumed at the location, building, or premises was used for fabr…
When did electricity sold to an awning fabricator qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate awnings for sale and at least 75% of all electricity consumed at the location, building, or premises was used for fabrication…
Were optical analysis and design services for an orbiting X-ray telescope subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the professional optical-engineering services used to analyze and design an orbiting X-ray telescope for a company performing a government contract were not s…
How did Connecticut source building-engineering services performed or billed across state lines?
Connecticut work for Connecticut projects was taxable even when billed out of state. Work for projects outside Connecticut was not taxable when the service's sole benefit and use occurred outside the …
Was a municipal building-permit fee taxable when an architect obtained the permit for a client?
No under this historical ruling when the architect separately stated the permit fee on the client bill. DRS treated the architect as the client's agent in obtaining the municipal permit. DRS says AN 9…
How were house-cleaning referral commissions and full-service cleaning receipts taxed under Connecticut Ruling 89-195?
A referral service's contractor commissions were taxable employment-service fees, while residents' direct payments to contractors were not. A cleaning service billing residents owed tax on total recei…
How did Connecticut source sales and use tax on multistate tool-sharpening services?
The ruling sourced the service to the property owner's location. A Massachusetts tool owner did not owe tax for Connecticut sharpening, while Connecticut owners owed tax whether sharpening occurred in…
Were engineering services for standby generator systems and related building modifications taxable under Connecticut Ruling 89-191?
Generator-system equipment design was not taxable, but engineering that designed the building or its modifications to house the equipment was taxable and had to be separately stated. DRS says AN 94(3)…
When did initial commercial finish-out count as nontaxable new construction rather than taxable renovation under Connecticut Ruling 89-190?
Initial finish-out of a new building, new addition, or first-sold office-condominium unit was nontaxable new construction. Work after initial finish-out—including changes for a new tenant in previousl…
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These are official tax letter rulings and advisory opinions issued by Connecticut's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.