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CT Ruling 90-66 Sales and Use Taxes 1990-09-25

Were commissions paid by commercial printers to an independent printing broker taxable sales-agent services in Connecticut?

Short answer: No under this historical ruling. Printing brokers solicited bids or placed client jobs with different commercial printers and charged the selected printer a fee. DRS treated them like independent commission salespeople representing many sellers, not an agent selling tangible personal property for one other person under Conn. Gen. Stat. § 12-407(2)(i)(U). DRS marks the ruling not current and obsoleted by AN 2000(8).

Apply this to your situation

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 based on the described printing-broker facts and law then in effect. DRS expressly marks it 'not current' and says it was obsoleted by Announcement (AN) 2000(8). Current broker and sales-agent service classifications must be confirmed. 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 -- obsolete historical guidance. DRS marks this ruling "not current" and states that it was obsoleted by Announcement (AN) 2000(8).

Plain-English summary

Printing brokers solicited bids or placed client printing jobs with different commercial printers, depending on the work required. The selected printer paid the broker a fee.

DRS held that the commissions were not taxable sales-agent services under Conn. Gen. Stat. § 12-407(2)(i)(U). The broker resembled an independent commission salesperson representing multiple sellers, rather than an agent selling tangible personal property for one other person.

What this means for you

The historical classification turned on the broker's independent, multi-printer role and who paid the fee. DRS later obsoleted the ruling, so current treatment must be checked.

Common questions

Who paid the broker? The commercial printer receiving the job.

Why was the commission not taxed? DRS did not treat the independent broker as a sales agent for one seller under the cited provision.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(U).
  • Announcement (AN) 2000(8) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 90-66, Sales Agent Services

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

Ruling 90-66

Sales Agent Services

This Ruling has been obsoleted by  AN 2000(8)

ISSUE:

Whether the services of a printing broker are subject to sales and use tax as "services of an agent of any person in relation to the sale of any item of tangible personal property for such person" under Section 12-407(2)(i)(U) of the General Statutes.

FACTS:

Printing brokers contact commercial printers either to solicit bids on printing jobs for their client accounts or to place printing jobs on behalf of their clients. Printing brokers typically place work with different commercial printers depending on the type of printed job required. Certain printing brokers specialize in placing certain types of printing jobs. The printing broker charges a fee to the commercial printer on jobs placed with it by the broker.

RULING:

The sales commissions paid to a printing broker for placing work with a commercial printer is not subject to sales and use tax under Section 12-407(2)(i)(U). The service of a printing broker are similar to those of an independent commission salesman who represents many sellers of goods, and are not considered to be sales agent services for selling tangible personal property for another person.

LEGAL DIVISION

September 25, 1990

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