CT Ruling 89-184 Sales and Use Taxes 1989-10-31

Which surveying, structural, site, roadway, drainage, and septic engineering services were taxable under Connecticut Ruling 89-184?

Short answer: Land surveying, survey work for subdivisions, structural building engineering, and road-construction stakeout were taxable. Site feasibility, site-development engineering, roadway and drainage design, and septic design were not. DRS says AN 94(3) obsoleted the ruling.

Apply this to your situation

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 engineering-service classifications then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. Its listed results for surveying, structural engineering, site work, roadway and drainage design, and septic design should not be assumed current. Connecticut imposes sales and use 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 your specific situation.
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 -- obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 94(3) obsoleted the ruling.

Plain-English summary

DRS treated land surveying for residential and commercial property as taxable. Subdivision work was taxable to the extent it involved surveying. Structural engineering for residential and commercial buildings and stakeout for road construction were also taxable.

Site feasibility studies, site-development engineering, roadway and drainage design, and residential or commercial septic design were not taxable.

What this means for you

The historical ruling classified each service separately rather than treating all engineering alike. AN 94(3) later obsoleted the guidance.

Common questions

Was land surveying taxable? Yes for residential and commercial property.

Was structural building engineering taxable? Yes.

Were site feasibility and site-development engineering taxable? No.

Were roadway, drainage, and septic design taxable? No under the ruling.

Citations and references

  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-184, Engineering

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

Ruling 89-184

Engineering

This Ruling has been obsoleted by   AN 94(3)

The following services listed in your letter are subject to tax:

  1. land surveying to both residential and commercial property;

  2. subdivisions of property, both residential and commercial, are taxable to the extent that land surveying services are involved;

  3. structural engineering for both residential and commercial buildings; and

  4. stake out for road construction is taxable as a land surveying service.

The following services are not subject to tax:

  1. site feasibility studies to both residential and commercial real estate;

  2. site development engineering to both residential and commercial real estate;

  3. roadway design, drainage, etc.; and

  4. septic designs - residential and commercial.

LEGAL DIVISION

October 31, 1989

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