Ezel / Tax Rulings / CT
CT Ruling 89-228 Utility Sales Tax 1989-11-21

Did X Foundation owe Connecticut sales tax on utility services purchased for its headquarters, including utilities associated with leased space?

Short answer: No under this historical ruling. DRS said no sales tax was due on utility services purchased by X Foundation, whose property, income, obligations, and activities were exempt under Conn. Gen. Stat. § 10a-209.

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 applying X Foundation's statutory tax exemption to the utility services it purchased. The result depended on the exemption in Conn. Gen. Stat. § 10a-209 and should not be extended to a different organization, exemption, purchasing arrangement, or current utility-tax rule. 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)

Plain-English summary

X Foundation had recently built a corporate headquarters and leased part of it. The request asked whether utility sales tax applied when gas or electricity consumption exceeded $150 and whether the answer changed when utilities for the tenant were included in base rent rather than separately billed.

DRS concluded that no sales tax was due on utility services purchased by X Foundation. The ruling states that the Foundation's property, income, obligations, and activities were exempt from taxes under Conn. Gen. Stat. § 10a-209.

What this means for you

The result was specific to X Foundation's statutory tax exemption. The brief ruling did not separately state different outcomes for the leased-space and base-rent arrangements described in the request.

Common questions

Did X Foundation owe sales tax on its utility purchases? No.

What exemption did the ruling cite? Conn. Gen. Stat. § 10a-209.

Did the ruling separately tax utilities included in the tenant's base rent? No separate result was stated; DRS broadly said no sales tax was due on utility services purchased by X Foundation.

Citations and references

  • Conn. Gen. Stat. § 10a-209, as cited in the ruling.

Source

Original ruling text

Ruling 89-228, Utility Sales Tax

Ruling 89-228

Utility Sales Tax

You state that beginning July 1, 1989, a sales and use tax was imposed on gas and electricity consumption exceeding $150.00. X Foundation's "property, income, obligations and activities" are exempt from taxes pursuant to Conn. Gen. Stat. § 10a-209. X Foundation recently constructed a building as its corporate headquarters and has leased a portion of the building.

You inquire whether you have an obligation to pay the sales and use tax (assuming consumption is greater than $150), and if utilities are included as part of the base rent, i.e., the tenant is not billed for utilities, whether there is still an obligation to pay the tax.

It is our opinion that no sales tax is due on utility services purchased by X Foundation.

LEGAL DIVISION

November 21, 1989

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