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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How were environmental assessments, remediation planning, underground-tank removal, ancillary design, and surveying inputs taxed under Connecticut Ruling 89-161?
Assessments, air/soil/water testing, ancillary sewer and septic design, licensed remediation planning, and underground-tank removal were not taxable. The engineer was final consumer of materials and t…
Which hydrology, highway, environmental, soil, site, approval, project-management, inspection, and surveying services were taxable under Connecticut Ruling 89-160?
The listed engineering, approval, estimating, management, supervision, and inspection services were not taxable. Boundary and topographic surveys and construction staking were taxable land surveying. …
Were emergency medical ambulance standby services at municipal, church, civic, or special private events subject to Connecticut sales tax?
No under this historical ruling. DRS said emergency medical ambulance services hired to stand by at municipal, church, civic, or special private events were not subject to sales tax.
Were sales, leases, or rentals transferring dominion and control of computer software subject to Connecticut sales and use tax?
Yes under this historical ruling. DRS treated software as tangible personal property, included leasing within sales, and said transferring dominion and control was a taxable lease or rental rather tha…
Were X Company's purchases exempt when an exempt resource-recovery facility reimbursed the company for the tax as an operating expense?
No under this historical ruling. X Company was not exempt, reimbursement did not convert its purchases into exempt purchases, and only direct purchases by the Bristol Resource Recovery Facility were e…
How did Connecticut tax accident-reconstruction engineering inputs, government reimbursable expenses, and multistate shopping-center management?
Licensed accident reconstruction was exempt, but the engineer owed tax on inputs and could not buy them for resale. Government-agency reimbursable expenses and management of a Connecticut shopping cen…
Did a precision sheet-metal manufacturer qualify for Connecticut's sales-tax exemption on electric bills?
Yes under this historical ruling. X Company manufactured precision sheet-metal components for aircraft, medical, and commercial uses to customer designs and specifications, and DRS said it qualified f…
Was the standalone creation of a freelance article taxable as consulting, public relations, advertising, or tangible personal property?
No under this historical ruling. Article creation without placement or dissemination involvement was not consulting or public relations, and the article was not taxable tangible personal property. The…
What documentation, billing, payment, and exemption-certificate conditions applied to Connecticut sales-tax exemption for federal credit unions?
The credit union had to establish federal status with organization documents, be billed directly, pay directly, and give each retailer a completed certificate for each sale. Employee-billed purchases …
Was a service that arranged trademark licensing agreements subject to Connecticut sales and use tax?
No. Based on the stated facts, the service provider arranged agreements between the trademark-owning corporation and manufacturers for use of the trademark, and DRS concluded that the arrangement serv…
Which building, roadway, roof, floor, addition, and demolition work counted as renovation or new construction under Connecticut Ruling 89-148?
The ruling classified a below-foundation floor expansion, a new building addition, and specified added space as new construction; parking-lot lowering, existing-road reconfiguration, and specified roo…
Did the described meat manufacturer qualify for Connecticut's sales-tax exemption on utility bills?
Yes under this historical ruling. The business cut or reshaped raw product, heat-treated it, changed product characteristics with seasonings, and formulated sausages. DRS concluded that it qualified f…
Were charges for storing fur coats or cloth coats subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-144 concluded that charges for storing fur coats or cloth coats were not subject to sales and use tax.
When were labor charges for installing, repairing, or replacing water systems taxable under Connecticut Ruling 89-142?
Installation labor was nontaxable for new construction and qualifying owner-occupied one-to-three-family residential property, but taxable for existing commercial or income-producing property. Repair …
Which boat-related training, storage, charter, washing, lifting, and surveying charges were taxable under Connecticut Ruling 89-141?
Classroom education, winter storage, mast removal, charter-location fees, lifting, and surveying were nontaxable; training sold with a boat and boat washing were taxable. DRS says 1996 Public Act 232,…
Were jewelry appraisals, jewelry or clock repairs, and engraving services taxable under Connecticut Ruling 89-140?
Jewelry appraisals were nontaxable. Jewelry and clock repair labor and parts were taxable. Engraving was taxable when part of a property sale but nontaxable when performed on customer-owned property. …
Were forensic engineering services subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-139 concluded that forensic engineering services were not subject to sales and use tax.
Were all receipts from Company X's valet parking service subject to Connecticut sales tax?
Yes. The total receipts were taxable because valet parking included all aspects of the parking service, including providing spaces, and the company could not break out a separate valet component. DRS …
How did Connecticut tax adjustment and testing of air-conditioning, heating, ventilation, and exhaust systems?
Adjustment receipts were taxable for residential or commercial real estate. Testing was nontaxable in new construction and existing one-, two-, or three-family exclusively residential owner-occupied p…
Did apple refrigeration equipment and a replacement compressor qualify for Connecticut's agricultural-production exemption?
Yes under this historical ruling. Refrigerating apples to prevent deterioration was direct use in agricultural production, so the replacement compressor qualified for a sales-and-use-tax refund. The r…
Were voice-over services provided to public relations agencies subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-135 concluded that providing voice-over services to public relations agencies was not subject to sales and use tax.
Were construction estimators' cost estimates for project feasibility studies subject to Connecticut sales tax?
No. The estimators prepared material-and-labor cost estimates but did not plan projects, so their work was outside the cited architectural, engineering, planning, design, and consulting service catego…
Were soil, earthen-material, and groundwater analysis and testing for engineering and environmental applications taxable?
No. Connecticut Ruling 89-133 concluded that analysis and testing of soils, earthen material, and groundwater for engineering and environmental applications were not among the taxable services listed …
Were union members' lobbying services exempt when the union put the lobbyists on its payroll and paid them?
Yes. Lobbying services were generally taxable, but services rendered by an employee to an employer were exempt. Because the union's members represented it, were on its payroll, and were compensated by…
Which fur storage, alteration, cleaning, repair, and remodeling charges were taxable under Connecticut Ruling 89-131?
Summer storage, alterations, and cleaning were nontaxable, while total receipts for fur repairs or remodeling were taxable. The furrier owed tax on materials and supplies used for storage, alterations…
Were the $6 daily food deductions from nursery employees taxable sales of meals after July 1, 1989?
Yes. Bulk food became meals when the employer's cook prepared it in ready-to-eat portions for 75 to 100 employees. Under the historical rule, under-$2 meals were exempt through June 30, 1989, but amou…
Were a physician director's medical-record analysis, research, and expert-witness location services for attorneys taxable consulting services?
No. The services were not taxable under the cited consulting-services provision because they were not advice about operating the attorneys' businesses. DRS says Announcement 94(4) obsoleted the ruling…
Were media-advertising receipts, including placement fees and development charges, subject to Connecticut sales and use tax?
No. Total receipts for media-advertising services, including placement and development charges, were nontaxable. The agency was the consumer of incorporated graphic designs, artwork, and mechanicals a…
When were equipment-service labor and preventive maintenance contracts taxable under Connecticut Ruling 89-127?
Labor after a 90-day free-service period was taxable. Preventive maintenance contracts commencing January 1, 1989 were nontaxable, but contracts entered into on or after July 1, 1989 were taxable. DRS…
Did a tobacco farmers cooperative qualify as a farmer engaged in agricultural production for the cited sales-tax exemption?
No. The cooperative steamed, fumigated, shipped, and sold members' tobacco as their agent, but did not raise or harvest the crop. Its activities were outside the cited definition of agricultural produ…
How did Connecticut Ruling 89-123 tax landscape design, contractor materials, and stone-fireplace labor?
Contractors paid tax on their materials. Landscape design was taxable. Fireplace labor was nontaxable for new construction and qualifying owner-occupied one-to-three-family homes but taxable for exist…
When did lawn-mowing work count as an occasional service rather than a taxable trade or business?
One to three residential lawn-mowing jobs per season by an individual outside a trade or business were occasional or casual. Ongoing mowing for one or more customers was a taxable trade or business. D…
Did electricity used by a bakery to produce baked goods qualify for Connecticut's manufacturing utility exemption?
Yes, if at least 75% of the electricity was consumed in the fabrication process. DRS says Policy Statement 94(3) superseded the ruling.
Did electricity used by an ice manufacturer qualify for Connecticut's manufacturing utility exemption?
Yes, when at least 75% of the electricity was consumed in fabricating the ice sold. The exemption applied only to electricity, not other purchases. DRS says PS 94(3) superseded the ruling.
How did Connecticut Ruling 89-119 distinguish exempt taxidermy services from taxable property sales?
Stuffing, preparing, and mounting customer-furnished animal remains were exempt services, with the taxidermist treated as consumer of supplies. Sales of skins, heads, mountings, or other tangible prop…
Did electricity used in printing operations qualify for Connecticut's manufacturing utility exemption?
Yes, if at least 75% of the electricity was consumed in fabricating the printed material. DRS says Policy Statement 94(3) superseded the ruling.
Did Connecticut Ruling 89-117 let furniture refinishers buy paint remover, stain, lacquer, and sandpaper for resale?
No. The ruling treated furniture refinishers as the final consumers of those materials and supplies, requiring them to pay sales and use tax when purchasing them. DRS says the ruling is not current an…
When did Connecticut Ruling 89-116 treat an initial building fit-out as nontaxable new construction rather than a taxable renovation?
Initial fit-out work was nontaxable new construction when it prepared never-used space for its first use or finished rental space before original occupancy. Prior use of unfinished space, including st…
How did Connecticut Ruling 89-115 tax copywriting, media advertising, collateral materials, and public-relations services?
Copywriting for media advertising or incorporation into collateral items was not taxable, and the total price of media advertising was not taxable. Total receipts for collateral items and public-relat…
How did Connecticut Ruling 89-114 tax sheet-metal contractors' materials, HVAC installation labor, repairs, and resale-certificate work?
Contractors paid tax on consumed materials. Installation labor was exempt for new construction and qualifying owner-occupied homes but taxable for existing commercial property; repair labor was taxabl…
How did Connecticut Ruling 89-113 treat landscape design, excavation, grading, land clearing, and septic-system work?
Landscape design and excavation, clearing, or grading integral to landscaping were taxable, including design for new construction. Those site-work services and septic installation were nontaxable for …
Did Connecticut Ruling 89-112 treat pond-dredging services as taxable maintenance services?
Yes. The ruling classified pond dredging as a taxable maintenance service under Conn. Gen. Stat. § 12-407(2)(i)(Z), as then amended. DRS says the information is not current and AN 2000(8) obsoleted th…
How did Connecticut Ruling 89-111 tax video-production equipment leases and an advertising agency's purchase of television video productions?
Video production did not qualify as manufacturing, so a production company's equipment lease was taxable. An advertising agency's purchase of video productions for television advertising was also taxa…
How did Connecticut Ruling 89-110 tax forestry management, timber-sale brokerage, soil testing, and land-planning services?
Total receipts for forestry management were taxable as landscaping, and timber-sale broker fees were taxable. Soil testing was exempt, and land planning was not taxable. DRS says AN 2000(8) partly obs…
Did Connecticut Ruling 89-109 impose sales and use tax on dance schools specializing in instruction or lessons?
No. The ruling said services by dance schools specializing in dance instruction or lessons were not subject to sales and use tax. DRS says the information is not current and AN 95(3) obsoleted the rul…
How did Connecticut Ruling 89-108 tax landscape design, lawn installation, and site work for residential, new-construction, and commercial property?
Landscape-design receipts and the full lawn-installation price were taxable. Separate site work was nontaxable for new construction and qualifying owner-occupied homes but taxable for existing commerc…
When did Connecticut Ruling 89-107 exempt electricity used to produce frozen desserts?
Electricity sold for direct use in producing frozen desserts was exempt if at least 75% was consumed in fabrication. The exemption covered only electricity, not other purchases. DRS says PS 94(3) supe…
Did Connecticut Ruling 89-106 tax freelance copywriting for print and radio ads or writing news releases?
No. Freelance copywriting for advertising agencies' print and radio advertising was not taxable. Writing news releases was also nontaxable if the service did not include influencing publication of art…
Did Connecticut Ruling 89-105 tax landscaping services supplied to a qualifying governmental district?
Ordinary landscaping receipts were taxable, but services for an entity qualifying as a district under Conn. Gen. Stat. § 7-324 were exempt when the district gave the landscaper a Governmental Agency E…
Did Connecticut Ruling 89-104 impose sales tax on land-planning and zoning-related services?
No. The listed land-planning services were nontaxable, including zoning studies, meeting representation, maps not included in land surveying, and land-use reports. DRS says AN 94(3) obsoleted the ruli…
How did Connecticut Ruling 89-103 tax graphic design for media advertising and for incorporation into printed materials?
Graphic-design receipts were taxable when supplied to advertising agencies for media advertising and when incorporated into brochures and other tangible items. Agency fees for media advertising were n…
Could a customer buy services to industrial, commercial, or income-producing real property tax-free for resale under Connecticut Ruling 89-102?
Only if the purchasing company had a Connecticut seller's permit. The services could be resold, but a purchaser without the permit could not buy them tax-free on a resale basis. DRS says AN 2000(8) ob…
When could architects use resale certificates to buy blueprints and other printing or duplication work under Connecticut Ruling 89-99?
Architects could use resale certificates only for printing and duplication passed directly to clients or others in the bid process. Any other use meant the architect consumed the work and owed tax. Bl…
Were forensic-engineering investigations for insurance and legal clients taxable under Connecticut Ruling 89-101?
No. Accident investigation, component-failure analysis, and fire-cause investigation were outside the cited categories for building engineering/design and business consulting or public relations. DRS …
Did Connecticut Ruling 89-100 preserve a municipality's exemption when architectural services and building materials were purchased through a private intermediary?
No. Direct contracts between the architect, subcontractors, and exempt entity qualified, with the required certificate. A private intermediary in a turn-key project became the purchaser, so the exempt…
Who had to collect Connecticut sales tax on firearms bought at a tax-exempt charity's auction: the auctioneer or the delivery agent?
The auctioneer was treated as the retailer and had to collect and remit tax on the firearm sales. The company that only transported the firearms to buyers under firearm regulations was not required to…
Were firearm sales subject to Connecticut sales tax under Ruling 89-96, or did the right to bear arms prevent the tax?
Firearm sales were taxable because firearms were tangible personal property and no stated exemption applied. The ruling also concluded that imposing sales tax on firearms did not tax or infringe the c…
Did Connecticut Ruling 89-94 include a lessee's property-tax reimbursement in the lessor's taxable gross receipts?
Yes, generally. A lessor's gross receipts included all amounts paid by the lessee, including property-tax reimbursement. The ruling identified an exclusion only for property-tax reimbursement under a …
When did Connecticut Ruling 89-91 impose sales tax on a gift certificate transaction: at purchase or redemption?
The gift certificate purchase was not taxable. The certificate became consideration when redeemed, and sales or use tax then applied to the total sales price of taxable merchandise purchased with it.
Was electricity sold for use in the municipal tax district described in Connecticut Ruling 89-90 taxable?
No. The ruling said electricity used in the municipal tax district qualified for the residential-dwelling exemption. DRS says the information is not current and PS 94(3) superseded the ruling.
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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.