Ezel / Tax Rulings / CT
CT Ruling 89-196 Sales and Use Taxes 1989-11-08

Was a municipal building-permit fee taxable when an architect obtained the permit for a client?

Short answer: No under this historical ruling when the architect separately stated the permit fee on the client bill. DRS treated the architect as the client's agent in obtaining the municipal permit. DRS says AN 94(3) 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 architect and building-permit fee rule then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. Its result depended on the architect acting as the client's agent and separately stating the municipal fee. 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

When an architect obtained a municipal building permit for a client, DRS treated the architect as the client's agent. The permit fee paid to the municipality was not taxable if the architect separately stated it on the client bill.

What this means for you

The historical result depended on agency and separate billing of the government fee. AN 94(3) later obsoleted the guidance.

Common questions

Was the municipal permit fee taxable? No under the stated conditions.

What billing condition applied? The architect had to separately state the fee on the client bill.

Citations and references

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

Source

Original ruling text

Ruling 89-196, Architectural

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

Ruling 89-196

Architectural

This Ruling has been obsoleted by   AN 94(3)

When an architect obtains a building permit from a municipality on behalf of a client, the architect is acting in an agency capacity for his client. The fee paid to the municipality for such permit is not subject to the sales and use tax as long as the architect separately states this item on his bill to his client.

LEGAL DIVISION

November 8, 1989

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