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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Were an accounting firm's economic and financial litigation-support services taxable as business analysis or management consulting in Connecticut?
No under this historical ruling. The accounting firm reviewed case materials, researched financial and business data, formed expert opinions, prepared exhibits and testimony, and assisted attorneys wi…
How did Connecticut historically tax services provided to condominium associations with both owner-occupied and leased units?
The 1990 ruling used three categories. Some services -- including landscaping, maintenance, janitorial, exterminating, design, locksmith, window cleaning, pool work, and tangible-property repair -- we…
Were trucking, hauling, packaging, and custom-crating services subject to Connecticut sales tax, and who paid tax on crate materials?
No under this historical ruling. Trucking and hauling were not enumerated taxable services, and packing, crating, and shipping were treated as personal services rather than sales of tangible personal …
Were basic warehouse storage services subject to Connecticut sales and use tax when no watchman or protective services were provided?
No. The company charged a stated price for warehouse storage and provided no watchman or protective service. DRS treated the transaction as rental of storage space rather than rental of tangible perso…
Were crane and rigging charges taxable when a company delivered, removed, and set production machinery in place without connecting or repairing it?
No. Setting machinery that did not become a structural building component was not a taxable service to industrial, commercial, or income-producing real property. Transporting, offloading, and reinstal…
Were crane and rigging charges taxable when a company lifted structural building components or modular offices into place but did no connecting, disconnecting, or repair work?
No. The company delivered, unloaded, placed, and removed air-conditioning compressors, trusses, headers, and relocatable modular office units, but did not connect or disconnect them or perform repairs…
Is a crane or trucking contract a taxable equipment rental when the company supplies the operator and controls how and when the equipment is used?
No. Customers hired the company to complete specific transportation or rigging jobs, not to use its equipment. The company always supplied the truck driver or crane operator and retained complete cont…
May a Connecticut lessor exclude insurance charges from taxable gross receipts on a tangible-personal-property lease?
Yes, but only when the insurance charge is separately stated and the lessee may either accept the lessor's insurance or obtain other coverage. Conn. Agencies Regs. § 12-426-25(c) excludes qualifying i…
Could printing trade vendors buy film, paper, chemicals, and other production inputs tax-free as resale or manufacturing materials?
Only materials physically incorporated into the product sold could be bought for resale under this historical ruling. DRS did not consider color separators, typesetters, or assemblers of mechanicals, …
Were consulting and public-relations services provided to a political candidate exempt from Connecticut sales and use tax?
No under this historical ruling. Conn. Gen. Stat. § 12-407(2)(i)(J) taxed consulting and public-relations services, and the law provided no exemption merely because the customer was a political campai…
Were sales and rentals of graduation gowns under $75 exempt from Connecticut sales and use tax, and was an exemption certificate required?
Yes under this historical ruling. Graduation-gown sales and rentals qualified as clothing costing under $75 under Conn. Gen. Stat. § 12-412(47), so the retailer did not need an exemption certificate. …
Which scrap-metal processing operations qualified as manufacturing for Connecticut sales and use tax exemptions?
Under this historical ruling, basic sorting, cutting, and baling -- including junk yards, auto wreckers, peddlers, collectors, and transfer stations -- did not qualify because they did not substantial…
How did Connecticut tax pharmaceutical sales to physicians, hospitals, nursing homes, clinics, and free drug samples?
Prescription drugs sold to physicians were exempt; nonprescription drugs were exempt only if listed in Conn. Gen. Stat. § 12-412(48). Federal and Connecticut government hospitals were exempt with a go…
Were a common carrier's Connecticut courier charges for picking up and delivering packages subject to sales and use tax?
No. The company was an authorized common carrier primarily picking up and delivering packages under 70 pounds between Connecticut offices and businesses, with additional interstate authority for Massa…
Were electronic speech aids for people after laryngectomy or permanent loss of larynx function exempt prostheses in Connecticut?
Yes. Because Medicare identified electronic speech devices as prosthetic devices, DRS treated oral-tube models that amplify sound into the mouth and throat-contact devices using a vibrating head as ex…
Were commissions paid by commercial printers to an independent printing broker taxable sales-agent services in Connecticut?
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 comm…
Were leases of industrial-gas bulk storage and vaporization tanks exempt as utility delivery equipment or manufacturing machinery in Connecticut?
No. The gas producer delivered liquid oxygen, hydrogen, helium, or nitrogen by tank truck into customer-site tanks that vaporized the product before a short pipeline carried it into the plant. The tan…
Which accessory tools, tool-holder parts, and measuring devices received Connecticut's manufacturing exemption or reduced historical tax rate?
Accessory tools and production-machine tool holders used directly in fabrication were exempt, as were collets functioning like exempt chucks. Parts of tool holders generally did not qualify for the re…
Were farm stands and farmers' markets treated as sellers of taxable meals, and which products remained taxable?
Traditional farm stands and farmers' markets were not sellers of meals under Bulletin No. 17, so farm-origin eggs, cider, seasonal fresh produce, honey, maple syrup, milk, and dairy products were not …
Could a leasing company issue resale certificates for labor on repairs, maintenance, and painting of property held exclusively for lease?
Yes under this historical ruling, effective for services on or after September 1, 1990. A lessor could issue a resale certificate for repair and maintenance services -- including vehicle painting -- p…
Were long-term employee-leasing charges taxable personnel services, and how were truck-driver services performed outside Connecticut allocated?
Yes under this historical ruling. An employee-leasing company paying drivers' wages, payroll taxes, and benefits owed sales and use tax on total gross receipts, including reimbursed employee expenses,…
Were services that monitored individual cable hookups to detect unauthorized reception by non-subscribers subject to Connecticut sales tax?
No. Local cable operators used the company to monitor individual hookups and identify non-subscribers using subscribers' lines without authorization. DRS held that this monitoring service was not amon…
Which parts of a shopping-mall expansion were nontaxable new construction rather than taxable renovation under Connecticut's historical rules?
New space above the former roof, the new roof, and work at or below the original ground-slab elevation were new construction. A partial floor was allocated 75% new construction and 25% renovation base…
Were independent dietetic counseling and kitchen-operation services provided to nursing homes taxable consulting services in Connecticut?
Yes under this historical ruling. The dietitian reviewed patient histories and eating habits, advised staff on special diets and food preparation, educated patients and families, and reviewed kitchen …
Were fees for servicing Connecticut Housing Finance Authority home mortgage loans subject to Connecticut sales and use tax?
No. Although mortgage servicing fees were generally taxable as a business management service under the historical rule, fees for servicing Connecticut Housing Finance Authority loans were exempt. CHFA…
How did Connecticut historically tax printing plates, pressroom materials, and outsourced or internally produced prepress items?
Raw plate materials and chemicals physically applied to the plate were exempt, as was an imaged ready-to-press plate. Ink and listed pressroom chemicals were used directly in manufacturing. Specified …
Was a custom full cranial hairpiece for a person with alopecia areata exempt from Connecticut sales and use tax?
Yes under this 1990 ruling, but it is no longer valid. DRS held that a Blundell Hairpiece custom-made from a mold of an alopecia areata patient's head qualified for the historical prosthesis exemption…
How did Connecticut historically tax cable-TV installation charges, separately billed cable FM audio service, and electricity used for video transmission?
Cable-TV installation was included in taxable community-antenna-TV gross receipts. Separately charged, audio-only cable FM service unconnected to video was not taxable. Electricity used for video tran…
Could a manufacturer buy clean-room air-purification machinery tax-free when the system was essential to growing gallium arsenide wafers?
Yes on the stated facts. DRS ruled that the air-purification machinery was used directly in the production process for growing gallium arsenide wafers. Because the clean room trapped particles and pol…
Were event tour packages combining tickets and bus or charter-air transportation subject to Connecticut sales and use tax?
No under the stated arrangement. X Corporation bought every package component at retail and paid applicable sales and admissions taxes. DRS treated the event ticket as an intangible right and ruled th…
Were asbestos-abatement consulting services excluded from Connecticut sales and use tax as services for voluntarily containing or removing hazardous waste?
Yes under this historical ruling. DRS treated asbestos as hazardous waste and excluded the listed assessment, bid, monitoring, clearance, and documentation services from tax as services for voluntary …
Were mortgage-servicing and related management services performed in Connecticut taxable when the mortgage holders were outside Connecticut?
No under the historical sourcing rule. Mortgage servicing was a taxable management service, but it was accepted or received where the mortgage holder was located, so services for out-of-state holders …
Did replacing an old building's entire internal structure count as new construction when two historic exterior brick facades remained?
Yes under the historical rule. The project created a new four-story building with new floors, support columns, walls, and internal materials; only two historic brick facades remained and were reanchor…
Were engineering design services taxable for plant equipment shelters and for a small mobile, easily disassembled control building?
Building-design services for private clients were taxable regardless of the building's use, including shelters for equipment at wastewater, solid-waste, or waste-treatment plants; municipal projects w…
Which fees charged at a dealer-to-dealer motor vehicle auction were taxable as services of a seller's agent?
Under this historical ruling, the selling commission, vehicle entry fee, and delayed title-work fee were taxable seller-agent services. The dealer registration fee, buyer's commission, and genuine veh…
Was a bank's mortgage servicing taxable when it continued collecting and processing payments after selling the mortgage?
Yes under this historical ruling when the service was rendered to or received by a Connecticut bank holding the mortgage loans. DRS classified mortgage servicing as a business analysis and management …
Were waiting-time fees, small-load charges, and separately stated delivery charges taxable on sales of ready-mix concrete?
Yes under this ruling. Waiting-time fees and minimum-load charges were part of the seller's gross receipts for ready-mix concrete. Delivery charges were also taxable when delivery occurred before titl…
Was a new-car package combining VIN window etching with theft insurance subject to Connecticut sales and use tax?
Yes. DRS treated the entire charge for the window-etching and theft-insurance package as part of the gross receipts from selling the new motor vehicle. The package remained taxable even when the deale…
Was a one-time cleaning of a newly constructed store taxable when performed before the certificate of occupancy?
Yes under this historical ruling. After the July 1, 1989 change, DRS treated janitorial services as taxable in all instances, including one-time cleaning before a new store received its certificate of…
Were charges for creating and maintaining a customer database, processing and updating mailing lists, and producing response reports taxable?
Yes under the historical rule. DRS treated the full receipts for creating and maintaining the computerized customer database, processing and updating mailing lists, and generating response-analysis re…
Was a stripped-down truck chassis exempt as a manufacturing component when converted into an aircraft ground-power vehicle?
Yes under the historical manufacturing exemption. X Company substantially altered the chassis and added a ground-power unit, producing a machine with a different name, nature, and use that supplied el…
Did Connecticut's historical sales-tax exemption for voluntary asbestos removal include an environmental consultant's related services?
Yes under this historical ruling. Because DRS had treated asbestos removal as exempt voluntary containment or removal of hazardous waste, the Commissioner interpreted that exemption to include an envi…
Were a wedding coordinator's full-service, partial-service, referral, or commission fees subject to Connecticut sales and use tax?
No under this historical ruling. DRS said wedding-coordinator service fees were not taxable, but tangible personal property sold by the coordinator was taxable. Tax on caterers, photographers, videogr…
Did converting a vacant manufacturing building into residential condominiums count as nontaxable new construction because the renovation cost exceeded the building's price?
No under this historical ruling. DRS treated work performed solely inside the existing building as a taxable renovation. The building's vacancy and the high renovation cost relative to its purchase pr…
Were cooperative direct-mail advertising services taxable when brochures, coupons, and flyers were mailed to Connecticut households?
Yes under this historical ruling. DRS treated preparing and distributing cooperative direct mail as taxable advertising, not exempt media advertising. The benefit was received at the advertising messa…
Were architectural services for the State of Connecticut exempt when a Connecticut contractor subcontracted some or all work to a related foreign corporation?
Yes under this historical ruling. Architectural services rendered to the State were exempt whether performed directly or through the subcontract. The Connecticut corporation could issue the foreign af…
Were rentals of automotive golf carts and pull-carts taxable at private, public, and municipal facilities?
Yes. The historical statute defined a sale to include leasing or renting tangible personal property of any kind. DRS therefore ruled that rentals of automotive golf carts and pull-carts were subject t…
Did the historical exemption for repairing nonbusiness motor vehicles cover labor on boats or snowmobiles?
No under this historical ruling. DRS said the exemption for repairs to motor vehicles not used in a trade or business did not apply to boats or snowmobiles. Labor charges for repairing either were the…
Were real estate appraisal services subject to Connecticut sales and use tax?
No under this ruling. Connecticut DRS stated that real estate appraisal services were not subject to sales and use tax.
Were bridge engineering services by licensed professional engineers taxable as building engineering services?
No under this historical ruling. DRS said bridge engineering by licensed professional engineers was not building engineering and therefore was not subject to sales and use tax. DRS marks the ruling no…
Were environmental-facility siting and remediation-design services taxable as building engineering or building design?
Generally no under this historical ruling. DRS excluded siting and design of landfills, impoundments, hazardous-waste facilities and incinerators, plus groundwater cleanup and remedial-program design.…
Were an architect's project inspections for a construction lender taxable as architectural work or business consulting?
They were taxable business consulting under this historical ruling, not exempt new-construction or architectural services. The architect verified a borrower's payment requests for the lending bank and…
Did nonprofit craft centers have to collect tax on craft and artwork sales and on consignment fees charged to artists?
Yes under this historical ruling. The exemption covered sales to qualifying nonprofits, not their sales to customers, apart from two permitted one-day events. Craft centers had to tax craft and artwor…
Which landscaping, surveying, stakeout, feasibility, engineering, roadway, drainage, and septic-design services were taxable?
Under this historical ruling, residential and commercial landscaping, subdivision surveying, and stakeout for real-estate development were taxable. Site feasibility studies, site-development engineeri…
Which farm-equipment repair and farm-structure charges were exempt or taxable under Connecticut's agricultural exemption?
Separately itemized repair parts for machinery used exclusively in agricultural production were exempt, but repair labor was taxable. Labor to renovate farm structures was taxable, while lumber, hardw…
When were construction-management services taxable for new construction, owner-occupied homes, and existing business property?
Under this historical ruling, construction management for new construction and existing one-, two-, or three-family exclusively residential owner-occupied property was not taxable. The same service fo…
Were auction sales of bank-repossessed tangible personal property and the auctioneer's fee to the bank taxable?
Yes under this historical ruling. The auctioneer had to collect tax on total gross receipts from selling the repossessed property. The auctioneer's fee charged to the bank was also taxable as a sales-…
What did a supplier have to do when drop-shipping merchandise to a Connecticut customer for an out-of-state retailer?
ABC Corporation complied by charging Connecticut tax to the out-of-state retailer when ABC delivered the merchandise to that retailer's Connecticut customer. Instead, ABC could accept through the reta…
Were gross receipts from providing expert-witness testimony subject to Connecticut sales and use tax?
No under this ruling. Gross receipts for rendering expert-witness testimony remained exempt from Connecticut sales and use tax under Conn. Gen. Stat. § 12-412(11).
Were guest greens fees, tennis-court fees, club-professional services, and the professional's property sales or leases taxable?
Under this historical ruling, a country club's greens fees and court-time fees charged to members' guests were not taxable, and club-professional services were exempt. But tangible personal property s…
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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.