Ezel / Tax Rulings / CT
CT Ruling 89-44 Capital Gains, Dividends and Interest Tax 1989-08-15

Did a partnership's capital gain recognized on January 10, 1989 qualify for Connecticut's 60% capital-gains exclusion?

Short answer: Yes. The ruling said the gain qualified because capital gains earned, actually or constructively received, accrued, or credited on or before February 8, 1989 were eligible for the 60% exclusion. The ruling is obsolete.

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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 The official page says it was obsoleted by Announcement 94(2), so it is provided only as historical reference and should not be used as current authority. It addressed the former capital gains, dividends and interest tax, a 60% exclusion, and a February 8, 1989 transition date under the law then in effect. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current individual and partnership taxation.
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

The partnership's capital gain recognized on January 10, 1989 qualified for the historical 60% capital-gains exclusion.

The ruling said gains earned, actually or constructively received, accrued, or credited to the taxpayer on or before February 8, 1989 were eligible for the exclusion.

The official archive says this ruling was obsoleted by Announcement 94(2).

What this means for you

The result depended on a specific transition date under a former Connecticut tax. The obsolete ruling does not establish current treatment of partnership gains.

Common questions

Did the January 10 gain qualify? Yes.

What was the cutoff date? February 8, 1989.

What events could place a gain before the cutoff? The ruling listed earning, actual or constructive receipt, accrual, or crediting to the taxpayer.

Citations and references

  • No statutory section number was cited in the ruling text.

Source

Original ruling text

Ruling 89-44, Capital Gains, Dividends and Interest Tax

This Ruling has been obsoleted by AN 94(2)

Ruling 89-44

Capital Gains, Dividends and Interest Tax

The capital gain recognized by the partnership on January 10, 1989 does qualify for the sixty percent capital gains exclusion. Under the new tax act, capital gains which are earned, received in fact or constructively, accrued or credited to the taxpayer on or before February 8, 1989 are eligible for such exclusion.

LEGAL DIVISION

August 15, 1989

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