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 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.
Did Connecticut Ruling 89-89 exempt electricity supplied through one meter to an apartment building used predominantly as residential dwellings?
Yes. Electricity sold to the single-meter apartment building was exempt if the building and its electricity use were predominantly for residential dwelling purposes. DRS says PS 94(3) superseded the r…
Were construction staking, locating and certifying buildings, and delineating wetlands taxable under Connecticut Ruling 89-88?
Yes. The ruling classified those functions as taxable land-surveying services under the cited statute. DRS says the information is not current and AN 94(3) obsoleted the ruling.
Were diet and weight-control counseling services taxable when a Connecticut weight-loss center provided no athletic or exercise facilities?
No. The ruling treated dieting and weight-control counseling by a weight-loss center without athletic or exercise facilities as nontaxable. DRS says the information is not current and AN 95(3) obsolet…
When did Connecticut Ruling 89-85 exempt electricity used by a bakery to manufacture baked goods?
The electricity was exempt if at least 75% was consumed in the bakery's production process. DRS says the information is not current and PS 94(3) superseded the ruling.
Did Connecticut Ruling 89-84 exempt real-estate appraisal charges for both homeowners and financial institutions?
Yes. Charges for real-estate appraisals were exempt under Conn. Gen. Stat. § 12-412(11), regardless of whether the appraisal was performed for a homeowner or a financial institution.
Did Connecticut Ruling 89-83 exempt electricity and gas sold to laundromats and dry-cleaning establishments as manufacturing utilities?
No. The ruling said laundromats and dry cleaners were not industrial manufacturing plants, so their electricity and gas were taxable and did not qualify for the cited manufacturing exemptions. DRS say…
Were a consultant's survey-coordination and interview-oversight services for marketing research companies taxable under Connecticut Ruling 89-82?
Yes. The consultant's hourly charges and reimbursed expenses were taxable, even though marketing research services themselves were exempt. Services for out-of-state clients were not taxable when their…
Did Connecticut Ruling 89-81 exempt charges for rendering a real-estate appraisal?
Yes. The ruling said a charge for rendering a real-estate appraisal was exempt from sales or use tax under Conn. Gen. Stat. § 12-412(11).
Did Connecticut Ruling 89-80 treat land surveyors as consumers of the property and services used in their work?
Yes. Land surveyors were the final consumers of tangible personal property and services purchased for use in performing surveying services, so they paid sales or use tax on taxable purchases.
Did Connecticut Ruling 89-79 exempt electricity used by printers in printing operations?
Yes, when at least 75% of the electricity was consumed in fabricating printed material. The official page says the information is not current and PS 94(3) superseded the ruling.
Were landscaping and related pond-excavation charges taxable under Connecticut Ruling 89-78?
Yes. Landscaping for new construction and existing residential or commercial property was taxable, including pond construction. Related excavation was taxable unless sold to the landscaper with a bona…
Did Connecticut Ruling 89-77 exempt electricity used by printers in printing operations?
Yes, when at least 75% of the electricity was consumed in fabricating printed material. The official page says PS 94(3) obsoleted the ruling and the information is not current.
Did Connecticut Ruling 89-76 exempt electricity used to store harvested fruit and produce in a farmer's cold-storage facility?
Yes. The ruling treated the cold-storage electricity as directly used in agricultural production because the farmer stored harvested fruit and produce there until sale. PS 94(3) later obsoleted the ru…
Did Connecticut Ruling 89-75 exempt electricity and gas used by greenhouse and nursery florists?
Yes, when the utilities were used directly in greenhouse or nursery agricultural production. Florists that merely bought cut flowers and made arrangements owed tax on their utility bills. PS 94(3) obs…
How did Connecticut Ruling 89-74 distinguish exempt engineering from taxable design or drafting services?
A licensed engineer's development of new engineering concepts and original product designs was exempt. Design or drafting services using the engineer's concepts, designs, and specifications were taxab…
Did Connecticut Ruling 89-73 exempt electricity for common-area lighting in predominantly residential apartment buildings?
Yes. When an apartment building was predominantly rented for residential dwelling purposes, electricity for inside hallway lights and exterior lighting was exempt. PS 94(3) later obsoleted the ruling.
Was electricity used to repair and recondition printed circuit boards taxable under Connecticut Ruling 89-72?
Yes. The ruling taxed electricity sold for use by repairers and reconditioners, including a business repairing and reconditioning printed circuit boards for key telephone systems. PS 94(3) superseded …
Was labor to install an above-ground pool on residential property taxable under Connecticut Ruling 89-71?
No, if the installation-labor charge was separately stated on the invoice. The ruling exempted the separately stated labor used to install or apply the above-ground pool sold.
Were conferences for the general public treated as business analysis and management services under Connecticut Ruling 89-70?
No. The Department said general-public seminars that provided specialized information did not fall within the cited business analysis and management services regulation. The ruling is obsolete and sup…
Could a condominium-management company continue prorating taxable gross receipts instead of taxing its full fee?
Yes under this historical ruling. The company could prorate its condominium-association management receipts by the ratio of leased, rented, or investment units to total units. DRS marks the ruling not…
Did a company fabricating complete dump-truck covers qualify for Connecticut's manufacturing exemption on electric bills under Ruling 89-69?
Yes. The Department concluded that machining, bending, painting, sewing, and assembling components into finished dump-truck covers for sale qualified the company for the electric-bill sales-tax exempt…
Were labor charges to repair heating, water-heating, and air-conditioning systems in small owner-occupied homes taxable under Connecticut Ruling 89-68?
Yes. The ruling treated repair-labor charges for heat pumps, water heaters, furnaces, air-conditioning units, and similar systems in owner-occupied one-, two-, or three-family homes as subject to sale…
Were post-loss home cleaning and nonscheduled rug or upholstery cleaning taxable under Connecticut Ruling 89-67?
Yes. The ruling treated cleaning a home's interior or contents after a fire, flood, or furnace malfunction as taxable janitorial service, and also taxed nonscheduled rug and upholstery cleaning in res…
Were testing or inspection services performed on tangible personal property taxable under Connecticut Ruling 89-66?
No. The ruling said testing or inspection services rendered to tangible personal property were not subject to Connecticut sales or use tax.
How did Connecticut Ruling 89-65 tax marketing research and related consulting services?
Marketing research was exempt, but advice to businesses about the research findings or results was taxable consulting. If exempt research and taxable consulting were not separately stated on the invoi…
Which real-property inspection services were taxable under Connecticut Ruling 89-64?
Inspections of existing commercial, industrial, or income-producing real property were taxable. Inspections of new construction and existing exclusively residential, owner-occupied one-, two-, or thre…
Was electricity used for residential dwelling purposes in a condominium complex exempt under Connecticut Ruling 89-63?
Yes. Electricity used in residential condominium units was exempt whether each unit was billed separately, rented to a residential tenant, or included in a single association bill for a predominantly …
Who had to pay or collect Connecticut use tax on pads delivered by an out-of-state seller under Ruling 89-62?
The Connecticut purchaser owed the tax. If the out-of-state seller met Public Act 89-41's registration requirement, it had to register, collect, and bill the tax; otherwise, if it did not register, th…
How did Connecticut Ruling 89-61 tax asbestos training programs and asbestos testing services?
The full gross receipts from asbestos training programs provided to businesses were subject to sales or use tax, while asbestos testing services were not taxable. The ruling is obsolete.
How did Connecticut Ruling 89-60 tax plan reviews, property inspections, and construction management services?
Specified new-construction and small owner-occupied residential services were not taxable, while services for existing commercial, industrial, or income-producing property were taxable. Work integral …
Were charges for planning and arranging business meetings or conventions taxable under Connecticut Ruling 89-58?
Yes. The ruling applied sales or use tax to the total gross receipts from planning and arranging business meetings or conventions, including discussing arrangements, formats, and agendas with clients.…
Was a church exempt from Connecticut corporation business tax without an IRS determination specifically recognizing its federal tax-exempt status?
No. The ruling required an IRS determination referring specifically to the church before the Connecticut corporation business tax exemption applied. The church could choose whether to file Form 1023, …
How did Connecticut Ruling 89-56 treat resale purchases of electricity or steam and gas used to produce utility service?
Electricity or steam bought for resale was not taxable if the purchaser gave the seller a resale certificate. Gas used directly to furnish steam or electricity through lines or pipes to consumers was …
Were lobbying services performed by an employee for the employer taxable under Connecticut Ruling 89-55?
No. The ruling said the lobbying-services tax did not apply when an employee performed the services for the employer as part of the employee's job duties. The ruling is obsolete.
How did Connecticut Ruling 89-54 tax management and property services for residential condominium associations?
Management, garbage removal, exterior painting, and road repair were taxable in proportion to non-owner-occupied units. Landscaping, furnace repair, and snowplowing were fully taxable even when every …
Did a class-reunion organizer have to collect sales tax on the full ticket price under Connecticut Ruling 89-53?
Yes. Because the organizer's arrangement fees were commingled with the event's catering, entertainment, and other costs, sales tax applied to the total ticket price. If the organizer contracted direct…
Which real-property inspection services were taxable under Connecticut Ruling 89-52?
Inspections of existing commercial, industrial, or income-producing property were taxable. Inspections of new construction and existing exclusively residential, owner-occupied one-, two-, or three-fam…
Were parts and labor to repair manufacturing production machinery taxable under Connecticut Ruling 89-51?
Yes. Repair or replacement parts and repair labor for production machinery were subject to 5.5% sales or use tax. The statute's $7,500 manufacturer refund applied to qualifying parts, not labor charge…
Were safety shoes selling for less than $75 taxable under Connecticut Ruling 89-50?
No, if the safety shoes were suitable for everyday use and their total sales price was less than $75. The ruling is superseded and the historical price threshold should not be assumed current.
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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.