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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Could a non-broadcaster providing television studios and post-production facilities claim Connecticut's broadcast-production equipment exemption?
No. The exemption applied only to television or radio stations, so the facility provider had to pay sales or use tax on its materials and equipment. Its charges to clients for using the facilities and…
Were monthly motor-vehicle lease payments taxable for lease periods beginning on or after July 1, 1989 under Connecticut Ruling 89-48?
Yes. Monthly motor-vehicle lease payments were subject to sales tax for lease periods on or after July 1, 1989. The referenced 90-day transition rule applied only to tangible-property sales contracted…
When were road or parking-lot grading services taxable under Connecticut Ruling 89-47?
On industrial, commercial, or income-producing property, grading for new roads or parking lots was not taxable, but grading to repair or rebuild existing ones was taxable. Residential grading was not …
Would Connecticut follow a corporation's federal I.R.C. § 338(h)(10) election when computing corporation business tax?
Yes. The Department concluded that Connecticut corporation business tax liability would follow federal law and incorporate the effects of the corporation's I.R.C. § 338(h)(10) election.
Were a new truck chassis and the separately stated charge to install it taxable under Connecticut Ruling 89-45?
The chassis sale was taxable, but a separately stated charge to install the new chassis on a motor vehicle for a truck dealer or end user was not. A truck dealer could buy the chassis for resale witho…
Did a partnership's capital gain recognized on January 10, 1989 qualify for Connecticut's 60% capital-gains exclusion?
Yes. The ruling said the gain qualified because capital gains earned, actually or constructively received, accrued, or credited on or before February 8, 1989 were eligible for the 60% exclusion. The r…
Were sales of gas or electricity to nursing or convalescent homes taxable under Connecticut Ruling 89-43?
No. The ruling exempted gas or electricity sold to nursing or convalescent homes for their use from sales or use tax. The ruling is superseded.
How did Connecticut Ruling 89-42 tax systems-design training provided to individuals and businesses?
Training provided to individuals was not taxable if it was not connected with a sale of tangible personal property. The same systems-design training provided to businesses was subject to sales or use …
How did Connecticut Ruling 89-41 determine the conveyance-tax rate for mixed-use property, and were realtor or appraisal services taxable consulting?
The conveyance-tax rate for mixed residential and commercial property followed the property's predominant use. The cited taxable-service provision did not tax realtor services for selling, leasing, or…
Which dry-cleaning and garment services were taxable under Connecticut Ruling 89-40?
Mending and deterioration-prevention work was taxable repair or maintenance, while separately stated alterations were not. Monogramming and embroidery were generally taxable, but fur storage, coin-ope…
Could later accumulated or credited dealer discounts reduce the taxable price of catalogs and advertising materials under Connecticut Ruling 89-39?
No. Both proposed discount methods left the normal selling price taxable because the discounts were not allowed and taken at the time of sale. Only a discount allowed by the company and taken by the d…
How did Connecticut Ruling 89-38 treat renovation services, tax-included billing, subcontractors, and installment payments?
New construction included services through first-tenant occupancy. A bill could say 'Tax Included' if records supported its components; the service portion equaled the total including profit minus mat…
Were aircraft brokerage services taxable when the aircraft sale and transfer of title occurred in Connecticut under Ruling 89-37?
Yes. The ruling applied sales tax to brokerage services when the aircraft sale, defined as the transfer of title, took place in Connecticut. The ruling is obsolete.
Which entertainment counted for Connecticut cabaret tax under Ruling 89-36?
Comedians, magicians, hypnotists, and disc jockeys counted as 'other entertainment.' A place serving or selling alcohol generally triggered cabaret tax when it charged for admission or refreshments an…
Were personal-residence inspection services taxable under Connecticut Ruling 89-35?
No. The ruling said personal-residence inspections were not subject to sales and use taxes. The official page says the ruling was later obsoleted in part.
How did Connecticut Ruling 89-34 tax driveway sealing and caretaker labor?
Driveway sealing was subject to sales tax, while labor for services performed as a caretaker was not. The official page says the ruling was later obsoleted in part.
Was gain from employees' forced stock sales in corporate takeovers subject to Connecticut's former capital-gains tax?
Yes. Because the forced-sale gains were taxable for federal income-tax purposes, the ruling also treated them as Connecticut capital gains under the former dividends, interest income, and capital gain…
Was X Company's humane animal-relocation service taxable under Connecticut Ruling 89-32?
No. Based on the facts in the request letter, the ruling said X Company's humane animal-relocation service was not subject to sales tax. The official page says the ruling was later obsoleted in part.
Were architectural services performed by an employee for the employer taxable under Connecticut Ruling 89-31?
No. Employee services for the employer were not subject to sales and use taxes even when the work was architectural, and the employee did not have to file Form REG-1 for those services. The ruling is …
Were vending-machine meal sales at the Veterans Home and Hospital exempt from Connecticut sales and use taxes under Ruling 89-30?
No. The ruling found no statutory exemption for X Company Food Services' vending-machine sales. The Veterans Home and Hospital was not the purchaser of the meals, so it also could not be liable for us…
Were services to paint business vehicles taxable, and could a vehicle lessor buy them for resale, under Connecticut Ruling 89-29?
Painting business vehicles, including vehicles leased to a business, was taxable. A motor-vehicle leasing company could not buy the painting service for resale because the lessor consumed the service.…
Did apartment buildings and rental homes retain Connecticut's residential gas-and-electricity exemption when managed for nonresident owners or temporarily vacant?
Yes. The ruling treated apartment buildings and rented houses as residential dwellings even when managed for nonresident owners, and vacant apartment units or rental homes retained the residential uti…
Were a real-estate firm's feasibility studies, site searches, comparative analyses, risk assessments, and organizational analyses taxable under Connecticut Ruling 89-27?
Yes. The ruling classified those real-estate advisory services to individuals and private or public entities as taxable business analysis, management, or consulting services. The ruling is obsolete.
Were custom software, software maintenance agreements, and installation charges taxable under Connecticut Ruling 89-26?
Yes. The ruling treated custom software as taxable tangible personal property, the related maintenance agreement as taxable computer-programming or processing service, and installation charges as part…
Were hoses, fittings, and hose assemblies sold to agricultural customers exempt under Connecticut Ruling 89-25?
Only when used directly in agricultural production. A customer with direct use issued an exemption certificate; indirect use remained taxable. The ruling is obsolete.
Did a hot-water heat exchanger used for handwashing qualify as machinery used directly in agricultural production under Connecticut Ruling 89-24?
No. The ruling treated the handwashing heat exchanger as indirectly used or outside agricultural production because the activity occurred before the first production operation. It contrasted machinery…
Could motor-vehicle dealers or repairers buy car-washing services for resale under Connecticut Ruling 89-23?
No. The ruling said dealers and repairers did not resell car-washing services to their customers and therefore could not give the car-wash provider a resale certificate. The ruling is obsolete.
Were appliance-repair services billed to a manufacturer under its warranty taxable after July 1, 1989 under Connecticut Ruling 89-22?
Yes. Repair and maintenance services performed on or after July 1, 1989 on tangible personal property, including appliances, were taxable. The official page marks the ruling obsolete and says the rema…
How did Connecticut Ruling 89-21 apply the July 1, 1989 commercial-renovation tax to existing contracts and carpet installation?
The new 8% tax applied to commercial, industrial, or income-producing renovation services performed on or after July 1, 1989, including existing contracts. Permanently affixed carpet made the full cha…
Could a contractor and subcontractor buy materials tax-free for a Connecticut construction agreement under Ruling 89-20?
Yes, for materials and supplies physically incorporated into and becoming a permanent part of the structure. The agreement was a construction contract, so Company X and subcontractor Company Y could g…
Could a farm purchaser use Connecticut's machinery exemption certificate for a screening plant under Ruling 89-19?
Yes. The screening plant was machinery used in the agricultural production process because it separated stones from soil to make fields more productive for cultivation. The purchaser could issue the m…
Did a laundry and dry-cleaning business qualify for Connecticut's manufacturing fuel exemption under Ruling 89-18?
No. Cleaning garments did not substantially transform property into a different product with a distinctive name, nature, and use, so it was not manufacturing and the fuel exemption was unavailable. Th…
How did Connecticut Ruling 89-17 tax cartons and packing materials used by moving companies?
Moving companies generally consumed their cartons, so purchases were taxable even if cartons were itemized, retained by customers, or used on moves. True over-the-counter sales were taxable retail sal…
How did Connecticut Ruling 89-16 define and apply the controlling interest transfer tax?
The tax was measured by the entity's interest in Connecticut real property and imposed on the transferor. A controlling interest meant more than 50% of corporate voting power or more than 50% of an en…
Were vocational and psychological testing services taxable in Connecticut under Ruling 89-15?
It depended on the customer. Vocational aptitude testing and counseling for the general public were not taxable. Psychological testing and profiles for prospective or existing employees were taxable s…
When did Connecticut petroleum gross earnings tax apply to advance deposits for diesel fuel under Ruling 89-14?
Not when the deposits were received. The tax applied only when the diesel fuel was sold because it was calculated on earnings from the first Connecticut sale of petroleum products.
Were commissioned economic writing services taxable in Connecticut under Ruling 89-12?
No. Writing a text analysis of Connecticut's economy for publication by a bank and a business newspaper was not subject to Connecticut sales and use tax under the ruling.
Were vehicle washing and cleaning services taxable in Connecticut under Ruling 89-11?
Not under the law applied to the request, because those services were not then enumerated as taxable. But the ruling's note says car washing became taxable after July 1, 1989, except coin-operated sel…
What did Connecticut Ruling 89-8 require for tax-included toy-truck promotions?
Advertisements using a tax-included price had to say 'tax included' or 'tax incl.,' including television and radio ads. The seller also had to provide a receipt on request showing the tax separately c…
Was a district's cholesterol screening charge taxable in Connecticut under Ruling 89-10?
No. The nominal charge covering testing materials and professional nurses' labor was for professional or personal services not described among the taxable services, so it was not subject to sales and …
When did Connecticut's production-materials exemption apply to a quarry's asphalt under Ruling 89-7?
The exemption applied when the quarry sold asphalt as a separately stated item. It did not apply when the quarry used asphalt in a construction contract and did not separately sell it.
Could a private developer buy sewer-system materials tax-free under Connecticut Ruling 89-6?
No. The governmental contractor exemption required a municipal-improvement contract paid with public funds. A municipality's benefit from developer-funded improvements required as a subdivision condit…
Were Treasury Trust Portfolio distributions subject to Connecticut's former dividends tax under Ruling 89-5?
Yes, when paid to shareholders who were natural persons residing in Connecticut. The government-obligation source did not change the result because the shareholders did not own those obligations. The …
Were an economic expert's litigation-support services taxable in Connecticut under Ruling 89-4?
No. The expert gathered and analyzed case data and presented opinions before a trier of fact for an attorney, rather than advising a business client. The services were not taxable business analysis or…
Did rebuilding automobile and truck engines qualify as manufacturing under Connecticut Ruling 89-3?
No. Rebuilding engines with new parts did not substantially transform them into a different product or form. Parts incorporated into engines for resale could be bought on a resale certificate, but mac…
Which customer sales were exempt from Connecticut use tax under Ruling 89-2?
Direct sales to Connecticut municipalities or their agencies were exempt if the government customer was directly billed, paid directly by its own check, and gave a completed exemption certificate. Sch…
Did a pro hac vice federal-court appearance count as practicing law in Connecticut under Ruling 89-1?
Yes, if the attorney was admitted by the judges of the superior court. Admission pro hac vice to represent a client in federal district court at Bridgeport counted as engaging in the practice of law i…
Does the published text of Connecticut Ruling 91-21 decide how 900 Commercial Service charges are taxed?
No conclusion is published. The official page describes a carrier's 900 Commercial Service and six sponsor offerings, but it contains no tax question, analysis, holding, or issue date.
Which landscaping, excavation, grading, sprinkler, lighting, sidewalk, and parking services were taxable under Connecticut's historical rules?
Planting trees, shrubs, and sod was taxable landscaping even at new construction. Excavation and rough grading for new construction were not taxable unless integral to landscaping; landscapers could b…
Is a corporation whose only income is partnership distributive shares from financial activities a 'financial service company' under Connecticut's corporation business tax?
Yes — it is a financial service company. A corporation whose entire gross income consists of its distributive shares from partnerships engaged wholly in 'financial service activities' is classified as…
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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.