Ezel / Tax Rulings / CT
CT Ruling 89-277 Sales and Use Taxes 1989-12-13

Were an engineer's study and maintenance recommendations for a harbor fuel-oil transfer pier taxable as building engineering or design services?

Short answer: No under this historical ruling. Studying a fuel-oil transfer pier, reporting its deficiencies, and recommending maintenance and corrective measures were not taxable building engineering or building planning/design services. DRS marks the ruling not current and obsoleted by AN 94(3).

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 reflecting the engineering-service classification then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 94(3) obsoleted it. Its treatment of a fuel-oil transfer-pier condition study and recommendations should not be assumed current or extended to design, construction, repair, or other engineering work. 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 ruling "not current" and states that it was obsoleted by Announcement (AN) 94(3).

Plain-English summary

A consulting engineer was hired to study the condition of a fuel-oil transfer pier at a Connecticut harbor facility, summarize its deficiencies, and recommend maintenance and corrective measures.

DRS ruled that those services were not taxable as building engineering or building planning/design under the historical provision.

What this means for you

The historical ruling distinguished a condition study and recommendations for an existing pier from taxable building engineering or design. AN 94(3) later obsoleted the guidance.

Common questions

What work did the ruling cover? Studying the pier's condition, reporting deficiencies, and making maintenance and corrective recommendations.

Were those engineering fees taxable? No under the ruling.

Does the ruling remain current? DRS says no; AN 94(3) obsoleted it.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as amended by 1989 Conn. Pub. Acts 251.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-277, Engineering

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

Ruling 89-277

Engineering

This Ruling has been obsoleted by  AN 94(3)

As described in your letter, you are a consulting engineer who has been commissioned to study and to report on the condition of a fuel oil transfer pier at a Connecticut harbor facility. In this capacity, you will study the condition of the pier, prepare a summary of its deficiencies and make recommendations for maintenance and corrective measures.

Your services are not subject to the sales and use tax as "building engineering and building planning or design services" under section 12-407(2)(i)(F) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

December 13, 1989

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