Connecticut State Tax Rulings
Free plain-English summaries of state tax letter rulings and advisory opinions issued in Connecticut, with full citations and the original source on every page.
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Which water- and sewer-plant engineering and building-design services were taxable under Connecticut Ruling 89-214?
General engineering was not taxable, but design work for a permanent building housing process facilities was taxable. Subcontracted building design could be bought for resale, while easily disassemble…
Was creating trade-show exhibits a manufacturing production process for Connecticut sales and use tax purposes?
No under this historical ruling. DRS said creating trade-show exhibits was not a manufacturing production process and instead was governed by the contractor regulations in Conn. Agencies Regs. § 12-42…
Which landscape-planning services were nontaxable, and was landscape architecture taxable, under Connecticut Ruling 89-212?
Site assessment, environmental-impact studies, schematic concepts, site planning, plan review, rezoning requests, and wetlands approval were not taxable. Landscape architecture was taxable as landscap…
Did prepress computers and peripheral equipment qualify for Connecticut's manufacturing machinery exemption?
No under this historical ruling. DRS said prepress production machinery was not used directly in manufacturing a finished product for sale and therefore did not qualify under Conn. Gen. Stat. § 12-412…
Did Company X have to collect sales tax on management services provided to partnerships owning Connecticut housing projects?
Yes under this historical ruling. The services were taxable, the low-income nonprofit housing exemption covered tangible property rather than services, and the partnerships had not shown qualifying no…
When were residential land clearing and excavation services taxable under Connecticut Ruling 89-208?
Land clearing solely for new residential construction was not taxable. Excavation for new commercial or residential construction was also nontaxable, but excavation on existing industrial, commercial,…
Which energy, power, environmental, and industrial engineering design services were taxable under Connecticut Ruling 89-206?
Listed energy, power, environmental, water-resource, and pulp-and-paper engineering was not taxable, but building engineering, building planning or design, building programs, and interior design were …
Were process-engineering services for industrial environmental problems subject to Connecticut sales and use tax?
No under this historical ruling. DRS said X Corporation's process-engineering services, including wastewater treatment and hazardous-waste management for industrial clients, were not taxable as buildi…
How did Connecticut source building-engineering services performed or billed across state lines?
Connecticut work for Connecticut projects was taxable even when billed out of state. Work for projects outside Connecticut was not taxable when the service's sole benefit and use occurred outside the …
Was a municipal building-permit fee taxable when an architect obtained the permit for a client?
No under this historical ruling when the architect separately stated the permit fee on the client bill. DRS treated the architect as the client's agent in obtaining the municipal permit. DRS says AN 9…
Which road, parking-lot, demolition, HVAC, appliance, and residential installation services qualified as new construction under Connecticut Ruling 89-194?
The ruling exempted specified new-road, new-parking-lot, and qualifying residential installations, but taxed listed pipe, resurfacing, demolition, existing-building HVAC, driveway, sealing, and repair…
Were engineering services for standby generator systems and related building modifications taxable under Connecticut Ruling 89-191?
Generator-system equipment design was not taxable, but engineering that designed the building or its modifications to house the equipment was taxable and had to be separately stated. DRS says AN 94(3)…
Were architects' feasibility studies evaluating whether office space met a client's needs subject to Connecticut sales and use tax?
Yes under this historical ruling. Studies evaluating whether office space had enough room for personnel, equipment, and expected growth were taxable building planning or design services. DRS says AN 9…
Were industrial wastewater-treatment and metal-finishing process-system design services subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the two listed process-system design services and the source letter's unspecified non-design efforts were not taxable under the building-engineering provision…
Was pond construction subject to Connecticut sales and use tax as a landscaping or horticultural service?
Yes under this historical ruling. Pond construction was taxable as landscaping and horticultural service work whether performed for residential or industrial, commercial, or income-producing property.…
Which surveying, structural, site, roadway, drainage, and septic engineering services were taxable under Connecticut Ruling 89-184?
Land surveying, survey work for subdivisions, structural building engineering, and road-construction stakeout were taxable. Site feasibility, site-development engineering, roadway and drainage design,…
How long was rent at the taxpayer's lodging house subject to Connecticut room-occupancy tax?
Rent for a room occupied for 30 consecutive calendar days or less was taxable. After the resident completed the thirtieth consecutive day, later rent was not taxable until continuity of the stay broke…
Was humane nuisance-wildlife removal from residential areas subject to Connecticut sales and use tax?
No under this historical ruling. The provider trapped raccoons, woodchucks, skunks, and similar animals, used no pesticides or poisons, did not kill them, and released them safely in state forests. DR…
When did Connecticut sales and use tax become due on an architect's retainer fee?
Tax became due when the architectural services were rendered or made available and the client became entitled to them, even if the architect received payment in an earlier or later filing period. DRS …
How were engine-repair labor and parts taxed for personal versus business vehicles under Connecticut Ruling 89-178?
Labor was exempt for a personal vehicle but taxable for a vehicle used in a trade or business; repair parts were taxable in both cases. Subcontracted parts and labor could be bought for resale with a …
Were total receipts from an airport valet lot taxable when the price bundled parking, vehicle relocation, and shuttle transportation?
Yes under this historical ruling. DRS treated the valet service as including a parking space and taxed total receipts, including airport shuttle transportation, without allowing allocation of part of …
When did an out-of-state architect have Connecticut sales-tax nexus and registration duties under Ruling 89-174?
Entering Connecticut to view a project site or inspect construction created nexus even when architectural work occurred elsewhere. Post-July 1, 1989 services were taxable despite an earlier contract, …
Could a landscaper accept a resale certificate for work under a federal, state, or municipal government construction contract?
Yes under this historical ruling when the landscaping benefited real property owned by the exempt government entity. Landscaping and tree removal were otherwise taxable on total gross receipts. DRS sa…
Which surveys, stakeout work, site plans, road and sewer designs, septic designs, and feasibility studies were taxable under Connecticut Ruling 89-167?
Boundary, topographic, plot-plan, mapping, and all listed stakeout services were taxable surveying. Road, sewer, utility, pond, site-plan, septic, hydraulic, hydrologic, and feasibility engineering we…
Were a detailer's simplified roofing and siding drawings subject to Connecticut sales and use tax as architectural or engineering services?
No under this historical ruling. The detailer extracted and condensed approved architectural and engineering information for bidding, materials, fabrication, erection, and field use, but DRS did not c…
Were systems-engineering services for glass machinery used to fabricate telescope optics subject to Connecticut sales and use tax?
No under this historical ruling. DRS said systems engineering for glass machinery used to fabricate telescope optics was not taxable under the building-engineering and design provision. DRS marks the …
Which hydrology, highway, environmental, soil, site, approval, project-management, inspection, and surveying services were taxable under Connecticut Ruling 89-160?
The listed engineering, approval, estimating, management, supervision, and inspection services were not taxable. Boundary and topographic surveys and construction staking were taxable land surveying. …
Which building, roadway, roof, floor, addition, and demolition work counted as renovation or new construction under Connecticut Ruling 89-148?
The ruling classified a below-foundation floor expansion, a new building addition, and specified added space as new construction; parking-lot lowering, existing-road reconfiguration, and specified roo…
How did a married couple filing separate federal returns have to file Connecticut's capital gains, dividends, and interest tax return?
They had to file separate Connecticut Capital Gains, Dividends and Interest Income Tax returns. DRS marks the information not current and says Announcement 94(2) obsoleted the ruling.
When were labor charges for installing, repairing, or replacing water systems taxable under Connecticut Ruling 89-142?
Installation labor was nontaxable for new construction and qualifying owner-occupied one-to-three-family residential property, but taxable for existing commercial or income-producing property. Repair …
Were all receipts from Company X's valet parking service subject to Connecticut sales tax?
Yes. The total receipts were taxable because valet parking included all aspects of the parking service, including providing spaces, and the company could not break out a separate valet component. DRS …
Were union members' lobbying services exempt when the union put the lobbyists on its payroll and paid them?
Yes. Lobbying services were generally taxable, but services rendered by an employee to an employer were exempt. Because the union's members represented it, were on its payroll, and were compensated by…
Which fur storage, alteration, cleaning, repair, and remodeling charges were taxable under Connecticut Ruling 89-131?
Summer storage, alterations, and cleaning were nontaxable, while total receipts for fur repairs or remodeling were taxable. The furrier owed tax on materials and supplies used for storage, alterations…
Were a physician director's medical-record analysis, research, and expert-witness location services for attorneys taxable consulting services?
No. The services were not taxable under the cited consulting-services provision because they were not advice about operating the attorneys' businesses. DRS says Announcement 94(4) obsoleted the ruling…
How did Connecticut Ruling 89-123 tax landscape design, contractor materials, and stone-fireplace labor?
Contractors paid tax on their materials. Landscape design was taxable. Fireplace labor was nontaxable for new construction and qualifying owner-occupied one-to-three-family homes but taxable for exist…
When did lawn-mowing work count as an occasional service rather than a taxable trade or business?
One to three residential lawn-mowing jobs per season by an individual outside a trade or business were occasional or casual. Ongoing mowing for one or more customers was a taxable trade or business. D…
Could a condominium-management company continue prorating taxable gross receipts instead of taxing its full fee?
Yes under this historical ruling. The company could prorate its condominium-association management receipts by the ratio of leased, rented, or investment units to total units. DRS marks the ruling not…
Which landscaping, excavation, grading, sprinkler, lighting, sidewalk, and parking services were taxable under Connecticut's historical rules?
Planting trees, shrubs, and sod was taxable landscaping even at new construction. Excavation and rough grading for new construction were not taxable unless integral to landscaping; landscapers could b…
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These are official tax letter rulings and advisory opinions issued by Connecticut's revenue authority in response to questions from specific taxpayers about how the tax law applies to their facts. A ruling is binding on the department only for the taxpayer who requested it and cannot be relied on by anyone else, but it is strong evidence of how the state reads the law. Every ruling above has a plain-English question and short answer, plus a link to the full original source.