Ezel / Tax Rulings / CT
CT Ruling 89-217 Corporation Business Tax 1989-11-15

Could capital losses reduce income other than net capital gains for Connecticut corporation business tax purposes?

Short answer: No under this historical ruling. DRS said capital losses under Conn. Gen. Stat. § 12-217(a) could be used only to offset net capital gains. In the cited examples, combined taxable income was $200, including $100 for Y Corporation.

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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 applying the corporation business tax capital-loss rule then in effect. The published text does not reproduce the examples behind its $200 combined-taxable-income result, so another taxpayer should not assume that calculation applies to different facts or current law. 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)

Plain-English summary

DRS stated that capital losses under Conn. Gen. Stat. § 12-217(a) could be used only to offset net capital gains.

For the examples supplied with the request, DRS said combined taxable income would be $200, with Y Corporation having $100 of taxable income. The published ruling does not include those underlying examples.

What this means for you

The historical ruling did not allow capital losses to offset income beyond net capital gains. Its numerical result cannot be reconstructed from the published text because the cited examples are absent.

Common questions

What could capital losses offset? Net capital gains only.

What combined taxable income did DRS report? $200.

How much taxable income did Y Corporation have? $100.

Citations and references

  • Conn. Gen. Stat. § 12-217(a), as cited in the ruling.

Source

Original ruling text

Ruling 89-217, Corporation Business Tax

Ruling 89-217

Corporation Business Tax

Please be advised that capital losses pursuant to section 12-217(a) of the Connecticut General Statutes may only be used to offset net capital gains. In the examples that you have cited, there would exist a combined taxable income of $200 (Y Corporation having taxable income of $100).

LEGAL DIVISION

November 15, 1989

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