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CT Ruling 89-54 Sales and Use Taxes 1989-08-15

How did Connecticut Ruling 89-54 tax management and property services for residential condominium associations?

Short answer: Management, garbage removal, exterior painting, and road repair were taxable in proportion to non-owner-occupied units. Landscaping, furnace repair, and snowplowing were fully taxable even when every unit was owner-occupied. The ruling is obsolete.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 The official page says it was obsoleted by Announcement 94(4), so it is provided only as historical reference and should not be used as current authority. It addressed specified management and property services for residential condominium associations 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 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

Management services for residential condominium associations were taxable in proportion to the number of units that were not owner-occupied compared with the total number of units.

Landscaping, furnace repair, and snowplowing were fully taxable even if every unit was owner-occupied. A property management company could buy those services for resale, but its charges to the association were fully taxable.

Garbage removal, exterior painting, and road repair were taxable in the same proportion as the non-owner-occupied units. A management company could also buy those services for resale, with its association charge taxable to that proportional extent.

The official archive says this ruling was obsoleted by Announcement 94(4).

What this means for you

The historical ruling did not apply one uniform rule to all condominium services. Some were fully taxable, while others followed the complex's owner-occupancy mix. Because the ruling is obsolete, current classifications must be verified separately.

Common questions

How were general management services taxed? In proportion to the share of units that were not owner-occupied.

Which services were fully taxable? Landscaping, furnace repair, and snowplowing.

Which services used the occupancy proportion? Garbage removal, exterior painting, and road repair.

Could a property manager buy the services for resale? Yes, but its charges to the association remained taxable as described in the ruling.

Citations and references

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

Source

Original ruling text

Ruling 89-54, Management

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

Ruling 89-54

Management

This Ruling has been obsoleted by  AN 94(4)

Generally, management services rendered for residential condominium associations continue to be subject to sales and use taxes to the same extent that the units that are not owner- occupied bear to the total number of units.

Landscaping, furnace repair and snowplowing services rendered for residential condominium associations are now subject to sales and use taxes, even if all the units are owner-occupied. (A property management company can purchase these services for resale to a condominium association. The charges made to the association for such services are fully taxable.)

Garbage removal, exterior painting and road repair services rendered for residential condominium associations are subject to sales and use taxes to the same extent that the units that are not owner-occupied bear to the total number of units. (A property management company can purchase these services for resale to a condominium association. The charges made to the association for such services are taxable to the extent described in the first sentence of this paragraph.)

LEGAL DIVISION

August 15, 1989

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