Ezel / Tax Rulings / CT
CT Ruling 90-13 Sales and Use Taxes 1990-02-01

When were installation, renovation, repair, and maintenance services taxable in owner-occupied and rented condominium units?

Short answer: Under this historical ruling, painting, carpentry, electrical, and plumbing labor billed directly to residents was nontaxable in owner-occupied units but taxable in rented units. Association-wide work was taxable in proportion to leased units. Repairs or maintenance to furnaces, heat pumps, water heaters, and air conditioners were taxable in all units. DRS later obsoleted the ruling in part.

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This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
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 is an official 1990 Connecticut Department of Revenue Services Ruling reflecting the condominium service rules then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 94(4) obsoleted it in part. Its owner-occupied, rental-share, and equipment-repair distinctions should not be assumed current or applied to different work or billing arrangements. 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 your specific situation.
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)

Note -- partly obsolete historical guidance. DRS marks this ruling "not current" and states that it was obsoleted in part by Announcement (AN) 94(4).

Plain-English summary

DRS gave different historical treatment to improvement labor and equipment repair at condominiums.

Painting, carpentry, electrical, and plumbing labor performed directly for residents inside individually owned units was not taxable when the unit was owner-occupied. The ruling's examples included installing a light fixture or water heater and replacing a leaky faucet. The same services were taxable when performed in rented condominiums.

When the condominium association hired a contractor for that work across the entire complex, tax applied in the same proportion that leased units bore to total units.

Repairs or maintenance to furnaces, heat pumps, water heaters, and air conditioners were taxable regardless of owner occupancy or rental use.

What this means for you

The historical ruling required identifying both the type of service and the unit's use. General improvement labor followed owner-occupancy and rental proportions, while listed equipment repair and maintenance remained taxable everywhere.

Common questions

Was plumbing labor inside an owner-occupied unit taxable? Not under the ruling when rendered directly to the resident.

How was association-wide work taxed? By the leased-unit share of the complex.

Were water-heater repairs exempt in owner-occupied units? No. Listed equipment repair or maintenance was taxable in all units.

Citations and references

  • Announcement (AN) 94(4) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 90-13, Installation and Repairs Services Condominiums

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

Ruling 90-13

Installation and Repairs Services

Condominiums

This ruling has been obsoleted in part by   AN 94(4)

Labor charges for painting services or carpentry services as well as electrical or plumbing services such as the installation of a light fixture, the installation of a water heater and the replacement of a leaky faucet rendered directly to the residents of "Condo Village" within their individually owned units, are not taxable when the units are owner occupied. The sales tax would apply to said services provided to rented condominiums. If a condominium association hires a contractor to render painting, carpentry, electrical or plumbing services to the entire condominium complex, the services are taxable in the same proportion as the number of leased units that bears to the total number of units in the complex.

Repairs or maintenance services performed on units, such as furnaces, heat pumps, water heaters and air conditioners are subject to sales tax regardless of whether the units are situated in owner-occupied condominium units or rental condominium units.

LEGAL DIVISION

February 1, 1990

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