Ezel / Tax Rulings / CT
CT Ruling 89-28 Sales and Use Taxes 1989-07-14

Did apartment buildings and rental homes retain Connecticut's residential gas-and-electricity exemption when managed for nonresident owners or temporarily vacant?

Short answer: Yes. The ruling treated apartment buildings and rented houses as residential dwellings even when managed for nonresident owners, and vacant apartment units or rental homes retained the residential utility exemption. The ruling is superseded.

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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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was superseded by Policy Statement 94(3), so it is provided only as historical reference and should not be used as current authority. It addressed gas and electricity for apartments and rental homes, including vacant units, under the law then in effect. 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 current residential utility exemptions.
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

Apartment buildings and houses rented to tenants were residential dwellings for the gas-and-electricity sales-tax exemption, including when they were managed for a nonresident owner.

Apartment units and rental homes also retained the exemption while vacant.

The official archive says this ruling was superseded by Policy Statement 94(3).

What this means for you

The historical ruling focused on residential character rather than owner occupancy or continuous tenant occupancy. Its superseded status means current billing, use, vacancy, and mixed-use rules must be verified separately.

Common questions

Did apartment buildings qualify? Yes.

Did rental houses managed for an out-of-state owner qualify? Yes.

Did a vacant unit lose the exemption? No, under this ruling.

Citations and references

  • No statute or regulation was cited in the ruling text.

Source

Original ruling text

Ruling 89-28, Utility Exemption - Residential

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

Ruling 89-28

Utility Exemption - Residential

This Ruling has been superseded by   PS 94(3)

You have inquired as to how the sales tax on gas and electric bills pertains to the property management industry.

In imposing a sales tax on certain uses of gas and/or electricity on or after July 1, 1989, the General Assembly clearly stated that residential use would be exempt.

Therefore, the term "residential dwelling" applies to apartment buildings and to houses being rented out and managed on behalf of the building's non-resident owner. In addition, during such periods when apartment units or rental homes are vacant, they are still considered to be residential dwellings and, as a result, retain their exemption from the sales tax.

LEGAL DIVISION

July 14, 1989

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