Ezel / Tax Rulings / CT
CT Ruling 89-199 Sales and Use Taxes 1989-11-08

When did electricity sold to an awning fabricator qualify for Connecticut's manufacturing utility exemption?

Short answer: It was exempt under this historical ruling when used directly to fabricate awnings for sale and at least 75% of all electricity consumed at the location, building, or premises was used for fabrication. DRS says PS 94(3) superseded the ruling.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 manufacturing electricity exemption then in effect for an awning fabricator. DRS expressly marks the information 'not current' and says Policy Statement (PS) 94(3) superseded it. Its result depended on direct fabrication use and a 75% location-wide electricity threshold and 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Note -- superseded historical guidance. DRS marks this information "not current" and states that Policy Statement (PS) 94(3) superseded the ruling.

Plain-English summary

Electricity sold to an awning fabricator was exempt when used directly in the actual fabrication of products for sale, provided at least 75% of all electricity consumed at the location, building, or premises was used for fabrication.

What this means for you

The historical exemption required both direct fabrication use and a 75% facility-level usage threshold. PS 94(3) later superseded the guidance.

Common questions

What activity had to use the electricity? Actual fabrication of awnings for sale.

What percentage threshold applied? At least 75% of electricity consumed at the location, building, or premises had to be used for fabrication.

Citations and references

  • Policy Statement (PS) 94(3) -- identified by DRS as superseding this ruling.

Source

Original ruling text

Ruling 89-199, Utility Exemption - Manufacturing

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

Ruling 89-199

Utility Exemption - Manufacturing

This Ruling has been superseded by   PS 94(3)

The sale of electricity to an awning fabricator for the direct use in the actual fabrication of the product to be sold is exempt from sales and use tax provided 75% or more of the electricity consumed at the location, building or premise is used for fabrication purposes.

LEGAL DIVISION

November 8, 1989

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