Ezel / Tax Rulings / CT
CT Ruling 89-49 Sales and Use Taxes 1989-08-15

Could a non-broadcaster providing television studios and post-production facilities claim Connecticut's broadcast-production equipment exemption?

Short answer: No. The exemption applied only to television or radio stations, so the facility provider had to pay sales or use tax on its materials and equipment. Its charges to clients for using the facilities and included equipment were not taxable. The ruling is superseded.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 The official page says it was superseded by Policy Statement 92(13), so it is provided only as historical reference and should not be used as current authority. It addressed one television production and post-production facility provider 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 media-production exemptions and service treatment.
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 company could not claim the broadcast-production exemption for materials and equipment because the exemption applied exclusively to television or radio stations. The company provided studios, editing rooms, and other post-production facilities but was not itself described as a television or radio station.

The company therefore had to pay sales or use tax on materials and equipment used in its facilities. Its charges to clients for using the facilities, including the equipment inside them, were not subject to sales or use tax under the ruling.

The official archive says this ruling was superseded by Policy Statement 92(13).

What this means for you

The historical ruling distinguished the facility provider's own taxable equipment purchases from its nontaxable charges to clients. It also read the cited exemption narrowly as limited to broadcast stations. Because the ruling is superseded, current media-production treatment must be checked separately.

Common questions

Did the facility provider qualify for the broadcaster exemption? No.

Were its materials and equipment purchases taxable? Yes.

Were client charges for facility and equipment use taxable? No, under this ruling.

Citations and references

  • Conn. Gen. Stat. § 12-412(44), as cited and quoted in the ruling.

Source

Original ruling text

Ruling 89-49, Broadcasting

This Ruling has been superseded by PS 92(13)

Ruling 89-49

Broadcasting

Company X is engaged in the business of providing television studios, editing rooms and other post production facilities to its clients who use the facilities for producing finished television programs for broadcast purposes.

Section 12-412(44) of the Connecticut General Statutes states:

Taxes imposed by this chapter shall not apply to the gross receipts from the sale of and the storage, use or other consumption in this state with respect to the following items . . . Sales of and the storage, use or other consumption of any materials or equipment which become an ingredient or component part or which are used directly in the production and transmission of finished programs broadcast to the general public by a television or radio station.

The exemption provided under section 12-412(44) applies exclusively to television or radio stations. Company X does not fall within the purview of section 12-412(44) and must pay sales or use tax for purchases of materials and/or equipment used in its facilities.

The charge to your clients for use of the facilities, including equipment contained therein, is not subject to sales or use tax.

LEGAL DIVISION

August 15, 1989

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