Ezel / Tax Rulings / CT
CT Ruling 89-134 Sales Tax 1989-10-06

Were construction estimators' cost estimates for project feasibility studies subject to Connecticut sales tax?

Short answer: 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 categories. DRS says AN 94(3) partly obsoleted the ruling.

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This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling reflecting the sales-tax service categories then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it in part, without identifying in this text which conclusion changed. The result depends on the estimators preparing cost estimates without planning the project. Connecticut imposes sales tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current treatment.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Note -- partly obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 94(3) obsoleted the ruling in part.

Plain-English summary

Construction estimators prepared project-feasibility cost estimates covering quantities of materials and labor. They did not plan projects, although they might sometimes change an item used in construction.

DRS concluded that their services were not taxable because they fell outside the cited categories for architectural, building-engineering, building-planning or design services and business-analysis, management, consulting, or public-relations services.

What this means for you

The historical result depended on the estimators' limited role in preparing costs rather than planning the construction project. AN 94(3) later obsoleted the ruling in part.

Common questions

What did the estimators prepare? Material-and-labor quantity and cost estimates for construction project feasibility studies.

Did they plan the project? No.

Were their services taxable? No under the cited historical provisions.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Conn. Gen. Stat. § 12-407(2)(i)(J), as cited in the ruling.
  • 1989 Connecticut Public Act 89-251, as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as partly obsoleting the ruling.

Source

Original ruling text

Ruling 89-134, Construction Estimators

This information is not current and is being provided for reference purposes only

This Ruling has been obsoleted in part by  AN 94(3)

You have made inquiry to our office as to whether the services of construction estimators are subject to the sales and use tax.

As we understand the nature of their work, construction estimators prepare cost estimates, including quantity of both materials and labor, for construction project feasibility studies. They are not involved in planning a project, although they might in some cases, change an item used in construction.

It is our opinion that the services rendered by construction estimators are not subject to the sales tax, because they do not come within the scope of Conn. Gen. Stat. §12-407(2)(i)(F) as "architectural, building engineering and building planning or design services" or Conn. Gen. Stat. §12-407(2)(i)(J) as "business analysis, management, consulting and public relations services", as amended by Public Act No. 89-251.

LEGAL DIVISION

October 6, 1989

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