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CT Ruling 89-267 Sales and Use Taxes 1989-12-08

Were health and athletic club service fees charged by a charitable nonprofit organization subject to sales and use tax?

Short answer: No under this historical ruling. Charges or fees for health and athletic club services provided by a charitable nonprofit organization were not subject to sales and use tax. DRS says AN 95(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 health-club service rules then in effect for a charitable nonprofit. DRS says Announcement (AN) 95(3) obsoleted it. Its exemption should not be assumed current or extended to noncharitable organizations, property sales, or different charges. 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 states that this ruling was obsoleted by Announcement (AN) 95(3).

Plain-English summary

DRS ruled that charges or fees for health and athletic club services provided by a charitable nonprofit organization were not subject to sales and use tax.

The short ruling does not discuss noncharitable clubs, sales or rentals of property, or bundled charges.

What this means for you

The historical result depended on both the provider's charitable nonprofit status and the charge being for health or athletic club services. AN 95(3) later obsoleted the guidance.

Common questions

Did every nonprofit club qualify? The ruling specifically says a charitable nonprofit organization.

Did the ruling address merchandise sales? No.

Citations and references

  • Announcement (AN) 95(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-267, Health and Athletic Clubs

This Ruling has been obsoleted by AN 95(3)

The charges or fees for health and athletic club services provided by a charitable non-profit organization are not subject to the sales and use tax.

LEGAL DIVISION

December 8, 1989

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