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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Which landscaping, surveying, stakeout, feasibility, engineering, roadway, drainage, and septic-design services were taxable?
Under this historical ruling, residential and commercial landscaping, subdivision surveying, and stakeout for real-estate development were taxable. Site feasibility studies, site-development engineeri…
Which farm-equipment repair and farm-structure charges were exempt or taxable under Connecticut's agricultural exemption?
Separately itemized repair parts for machinery used exclusively in agricultural production were exempt, but repair labor was taxable. Labor to renovate farm structures was taxable, while lumber, hardw…
When were construction-management services taxable for new construction, owner-occupied homes, and existing business property?
Under this historical ruling, construction management for new construction and existing one-, two-, or three-family exclusively residential owner-occupied property was not taxable. The same service fo…
Were auction sales of bank-repossessed tangible personal property and the auctioneer's fee to the bank taxable?
Yes under this historical ruling. The auctioneer had to collect tax on total gross receipts from selling the repossessed property. The auctioneer's fee charged to the bank was also taxable as a sales-…
What did a supplier have to do when drop-shipping merchandise to a Connecticut customer for an out-of-state retailer?
ABC Corporation complied by charging Connecticut tax to the out-of-state retailer when ABC delivered the merchandise to that retailer's Connecticut customer. Instead, ABC could accept through the reta…
Were gross receipts from providing expert-witness testimony subject to Connecticut sales and use tax?
No under this ruling. Gross receipts for rendering expert-witness testimony remained exempt from Connecticut sales and use tax under Conn. Gen. Stat. § 12-412(11).
Were guest greens fees, tennis-court fees, club-professional services, and the professional's property sales or leases taxable?
Under this historical ruling, a country club's greens fees and court-time fees charged to members' guests were not taxable, and club-professional services were exempt. But tangible personal property s…
When were installation, renovation, repair, and maintenance services taxable in owner-occupied and rented condominium units?
Under this historical ruling, painting, carpentry, electrical, and plumbing labor billed directly to residents was nontaxable in owner-occupied units but taxable in rented units. Association-wide work…
Was a service that collected customer mail, packaged it, and delivered it for shipment to foreign countries taxable?
No under this ruling. X Company's couriers collected mail from customer offices, brought it to X's office for packaging, and delivered it for shipment overseas. DRS said the described international ma…
How were the sale, installation, and removal of an underground storage tank taxed?
The tank sale was taxable. Installation was not taxable if separately stated, but the full gross receipts were taxable when installation was bundled with the tank charge. Removing an underground stora…
When were masonry and sprinkler installation taxable, and were landscaping and tree-removal services taxable?
Under this historical ruling, masonry and sprinkler installation were taxable on existing commercial, industrial, or income-producing property but not at new construction or qualifying owner-occupied …
Was sharpening or resharpening cutting tools used in manufacturing taxable, and could the manufacturer issue an exemption certificate?
Under this historical ruling, sharpening manufacturing cutting tools was a taxable repair or maintenance service. The manufacturer could not issue a resale certificate or manufacturer's exemption cert…
Was a service that addressed, folded, enclosed, sealed, and mailed customer-provided literature subject to sales and use tax?
No under this historical ruling. X Company used postal cards or stamped envelopes to mail customer-provided literature and separately stated postage on its bills. DRS ruled that the mailing service wa…
Were employee meal charges and the corporation's subsidy payments to a corporate-cafeteria vendor subject to sales tax?
The cafeteria's total gross receipts from meal charges to employees were taxable. The corporation's separate subsidy payments to the food vendor were not subject to sales tax.
Were a private golf club's golf-cart rentals, greens fees, locker rentals, and bag-storage fees taxable?
Under this historical ruling, golf-cart rentals were taxable rentals of tangible personal property. Greens fees, locker rentals, and bag-storage fees were not subject to sales and use tax. DRS marks t…
How did a general contractor handle tax on subcontracted services for an out-of-state customer, especially when the services also benefited the contractor?
Under this historical ruling, the contractor could buy subcontracted taxable services for resale and charge tax to the ultimate consumer. No tax applied when the foreign customer received the service …
Which guest-use and instruction charges at a member-owned private country club were excluded from sales and use tax?
Under this historical ruling, guest golf, swimming, paddle-tennis, tennis, beach-club, and shooting-club fees were not subject to sales and use tax. Golf, swimming, paddle-tennis, and tennis lessons f…
Was conveying an interest in real property subject to state and municipal conveyance taxes when the interest was encumbered?
Yes under this ruling. An encumbered real-property interest was treated as conveyed for consideration and was therefore subject to both Connecticut state and municipal real estate conveyance taxes.
Was natural gas bought by a cogeneration facility exempt when used directly to furnish steam and electricity to consumers through mains, lines, or pipes?
Yes under this ruling. X Company's natural gas purchases were exempt to the extent the gas was used directly to furnish steam or electricity delivered to consumers through mains, lines, or pipes. The …
Did take-out pizza and pizza-delivery businesses qualify for the manufacturing exemption on electricity purchases?
No under this historical ruling. DRS treated the businesses as preparing and furnishing meals for immediate consumption, not as manufacturers or fabricators operating industrial plants. They could not…
How were civil engineering, subcontracted land surveying, landscaping, and services connected with State projects taxed?
Under this historical ruling, the firm's civil engineering was not taxable building engineering. Boundary and topographic surveys bought from land-surveyor subcontractors were taxable and could not be…
Did transferring all shares of a Panama corporation holding Connecticut real estate to a commonly owned Barbados corporation trigger transfer taxes?
Yes. DRS treated the share transfer as one for consideration and subject to controlling-interest transfer taxes. The ruling also said that if the Panama corporation were domesticated into Delaware thr…
Could a tax-exempt religious institution buy a vehicle without sales tax when it paid the full price but registered the vehicle in its rabbi's name?
Yes under this ruling. When the institution paid the full price, bought the vehicle solely for religious purposes, and used its rabbi's name only for insurance and liability reasons, the dealer could …
Were an engineer's study and maintenance recommendations for a harbor fuel-oil transfer pier taxable as building engineering or design services?
No under this historical ruling. Studying a fuel-oil transfer pier, reporting its deficiencies, and recommending maintenance and corrective measures were not taxable building engineering or building p…
Were engineering services for improvements and modifications to utilities' existing fuel systems taxable as building engineering or design?
No under this historical ruling. A consulting engineer's designs for safe and reliable operation of local electric utilities' existing fuel systems or processes were not taxable building engineering o…
Which subcontractor services on a State of Connecticut project were exempt, and which incidental services remained taxable?
Services that were integral, inseparable components of the architect's ultimate design service to the State were exempt, normally including engineering, land surveying, and landscaping. Incidental ser…
Were total landscaping receipts taxable, and could landscapers buy bolts, cables, and lags for resale?
Under this historical ruling, total gross receipts for landscaping services were taxable. Landscapers could buy bolts, cables, and lags tax-free for resale by giving suppliers valid resale certificate…
Were manufacturing tool-resharpening services taxable when performed inside or outside Connecticut?
Yes under this historical ruling. Beginning July 1, 1989, repair and maintenance services to tangible personal property were taxable, including tool sharpening obtained by Connecticut companies even w…
Were fees for martial-arts, tennis, or gymnastics lessons subject to sales and use tax?
No under this historical ruling. Fees charged for lessons in martial arts, tennis, or gymnastics were not subject to sales and use tax. DRS marks the ruling not current and obsoleted by AN 95(3).
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…
Could the Commissioner extend X Company's statutory deadline for reporting personal property located in Connecticut towns?
No. After reviewing the governing public act, the Commissioner concluded that he had no statutory authority to extend the legislatively established filing deadline and denied X Company's request for a…
Were model usage fees taxable, and could an advertising agency give the model agency a resale certificate?
The model usage fees were taxable as an employment service. The advertising agency using the models was the ultimate consumer, had to pay sales tax on the model agency's fee, and could not issue a res…
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…
Which facilities counted as residential for the exemption from sales tax on gas, electricity, and heating fuel?
Under this historical ruling, apartment buildings, nursing homes, congregate housing, and halfway houses were residential and exempt for gas, electricity, and heating fuel. Hospitals, hotels, and mote…
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…
Did nursing homes and similar long-term health or chronic-care facilities qualify for Connecticut's residential utility exemption?
Yes under this historical ruling. DRS treated convalescent or nursing homes as residential, allowing them to claim the exemption through their utility and heating-oil suppliers and receive bill credit…
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 …
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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.