Ezel / Tax Rulings / CT
CT Ruling 89-5 Capital Gains, Dividends and Interest Tax 1989-04-03

Were Treasury Trust Portfolio distributions subject to Connecticut's former dividends tax under Ruling 89-5?

Short answer: Yes, when paid to shareholders who were natural persons residing in Connecticut. The government-obligation source did not change the result because the shareholders did not own those obligations. The ruling is obsolete.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), and it addressed Connecticut's former capital gains, dividends and interest tax. It is provided only as historical reference and should not be used as current authority. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current taxation of investment distributions.
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

Distributions from the Treasury Trust Portfolio were subject to Connecticut's former dividends tax when the shareholders were natural persons residing in Connecticut.

The distributions came from direct U.S. Government obligations and repurchase agreements collateralized by those obligations. That source did not change the result because the shareholders did not themselves own the government obligations.

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

What this means for you

This is a historical ruling about a former Connecticut tax. Its distinction was between a fund's underlying government obligations and the shareholder's ownership of the portfolio interest.

Common questions

Which shareholders were covered? Natural persons who were Connecticut residents.

Did the government-obligation source make the distribution nontaxable? No.

Why not? The shareholders were not the owners of the underlying obligations.

Citations and references

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

Source

Original ruling text

Ruling 89-5, Capital Gains, Dividends and Interest Tax

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

Ruling 89-5

Capital Gains, Dividends and Interest Tax

This Ruling has been obsoleted by AN 94(2)

The distribution paid to shareholders of the Treasury Trust Portfolio would be subject to the dividends tax, where those shareholders are natural persons who are residents of Connecticut. The fact that the distributions are derived from direct U.S. Government obligations and from repurchase agreements collateralized by U.S. Government obligations is not pertinent, because the shareholders are not the owners of such obligations.

LEGAL DIVISION

April 3, 1989

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