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.

530 rulings · Updated July 28, 2026
26 rulings New Construction

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Is the labor to install a fuel cell facility on real property a taxable service in Connecticut, or is it exempt as new construction / a site improvement?

The labor to install the fuel cell facility is a service to real property, not the installation of tangible personal property. And because the facility is a site improvement (construction of new real …

2019-06-25

When a building is gutted to its outer walls, are the construction services taxable renovation or exempt new construction in Connecticut?

Mostly untaxed new construction -- with one taxable exception. A company kept only the exterior walls of a former warehouse and built a new gabled skylight roof (adding cubic footage), new interior wa…

1993-05-20

How are hazardous-waste cleanup, remediation, and related site services taxed under Connecticut's services-to-real-property tax?

It splits several ways. A company cleaned up hazardous waste at industrial and commercial sites -- decontaminating facilities and running groundwater/soil remediation. Connecticut taxes services to in…

1992-08-05

Which parts of a gas pipeline are tax-exempt 'materials used directly in the furnishing of gas,' and is building the pipeline a taxable service?

Partly exempt. An interstate gas-pipeline company bought the components of a new Connecticut pipeline. DRS split them: the PIPE and the VALVE ASSEMBLIES and CONNECTORS are 'materials used directly in …

1992-04-20

Which parts of a shopping-mall expansion were nontaxable new construction rather than taxable renovation under Connecticut's historical rules?

New space above the former roof, the new roof, and work at or below the original ground-slab elevation were new construction. A partial floor was allocated 75% new construction and 25% renovation base…

1990-07-23

Did replacing an old building's entire internal structure count as new construction when two historic exterior brick facades remained?

Yes under the historical rule. The project created a new four-story building with new floors, support columns, walls, and internal materials; only two historic brick facades remained and were reanchor…

1990-04-27

Was a one-time cleaning of a newly constructed store taxable when performed before the certificate of occupancy?

Yes under this historical ruling. After the July 1, 1989 change, DRS treated janitorial services as taxable in all instances, including one-time cleaning before a new store received its certificate of…

1990-04-03

Did converting a vacant manufacturing building into residential condominiums count as nontaxable new construction because the renovation cost exceeded the building's price?

No under this historical ruling. DRS treated work performed solely inside the existing building as a taxable renovation. The building's vacancy and the high renovation cost relative to its purchase pr…

1990-03-07

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…

1990-02-05

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 …

1990-01-31

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…

1989-12-07

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…

1989-12-07

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…

1989-12-07

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…

1989-11-15

When were residential land clearing and excavation services taxable under Connecticut Ruling 89-208?

Land clearing solely for new residential construction was not taxable. Excavation for new commercial or residential construction was also nontaxable, but excavation on existing industrial, commercial,…

1989-11-13

Which road, parking-lot, demolition, HVAC, appliance, and residential installation services qualified as new construction under Connecticut Ruling 89-194?

The ruling exempted specified new-road, new-parking-lot, and qualifying residential installations, but taxed listed pipe, resurfacing, demolition, existing-building HVAC, driveway, sealing, and repair…

1989-11-07

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…

1989-11-06

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…

1989-10-12

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…

1989-09-26

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…

1989-09-26

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…

1989-09-26

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…

1989-08-22

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…

1989-08-15

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 …

1989-08-15

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…

1989-08-01

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…

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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.

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