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.
No Connecticut rulings match these filters
Try a different search term or clear the filters.
Is a chemist's paid consulting on the chemical properties of a manufacturer's products a taxable business-management service in Connecticut?
No. A chemist with advanced degrees who consults on the chemical properties of a manufacturer's hair care and hair color products is NOT providing taxable 'business analysis, management, management co…
When a temporary worker's staffing contract is renewed until the worker becomes a 'leased employee,' can the agency stop charging Connecticut sales tax on the worker's wages and benefits?
Only going forward, once the worker actually qualifies as a 'leased employee.' A staffing agency's charges for separately stated compensation, fringe benefits, workers' compensation, and payroll taxes…
If a car-lease company refunds a lessee an end-of-lease adjustment because the returned vehicle sold for more than its book value, does that reduce taxable receipts and require refunding the sales tax?
Yes. When a motor-vehicle leasing company's end-of-lease 'rental charge adjustment' runs in the LESSEE's favor — because the company sold the returned vehicle for MORE than its book value and pays the…
Are a licensed pharmacist's consultation services to nursing homes — including in-service training of staff — taxable business-management services in Connecticut?
No. A licensed pharmacist's 'pharmacy consultation services' to skilled and intermediate care nursing facilities — monthly review of drug appropriateness, reviewing dosages, assessing drug regimens, m…
Is a company's transfer of an entire manufacturing division's assets into new subsidiaries exempt from Connecticut sales and use tax as a casual sale?
Yes (with two carve-outs). When a large manufacturer converts a division into new subsidiaries by contributing all of the division's assets and liabilities — inventory, materials, tools, fuel, machine…
Is a licensed casualty adjuster's insurance investigation and claims-adjusting work a taxable business-management or private-investigation service in Connecticut?
No, on both counts. A company licensed as a 'casualty adjuster' that investigates and adjusts insurance claims for insurers — accident reconstruction, surveillance, interviews, polygraphs, document an…
Are marketing consulting and consumer test-market workshops taxable 'business public relations services' in Connecticut?
No. A company that assesses a client's product marketing, advises on better marketing strategies, and runs 'workshops' using members of the public to test those strategies is NOT providing taxable 'bu…
Which of a scrap-metal recycler's machines, materials, fuel, and power qualify for Connecticut's manufacturing and fabrication tax exemptions?
It splits by machine. A scrap-metal recycler's SHREDDER (with its shaker table and magnetic separators) — which pulverizes whole cars and appliances into separated 'frag' and other outputs — IS exempt…
Is a service that finds a judgment debtor's attachable assets for a creditor a taxable credit-reporting or private-investigation service in Connecticut?
No, on both counts. A company that searches by phone and computer to locate a judgment debtor's attachable assets for a judgment creditor — and just delivers a written asset report — is NOT providing …
Does the electricity used in a newspaper's prepress-operations building qualify for Connecticut's manufacturing/fabrication utility exemption?
No. The electricity used in the building that houses a newspaper's PREPRESS operations (advertising, composing, art, camera, editorial, darkroom, classifieds) does NOT qualify for the utility exemptio…
Is testing underground storage tanks for leaks to comply with environmental law a taxable service to real property or a taxable tank repair in Connecticut?
No, on both counts. Testing underground storage tanks at service stations (and the related monitoring wells and test pits) to comply with state and federal environmental laws is a service rendered for…
When worn grinding wheels are stripped and re-coated, is that exempt manufacturing, an exempt material purchase, or taxable repair in Connecticut?
It splits into three parts. Replating a worn grinding wheel is NOT the 'manufacture of a tool' under Conn. Gen. Stat. §§ 12-412(18) and (34) — a grinding wheel goes in and a grinding wheel comes out (…
Is the software a manufacturer uses to run its computerized milling machines exempt from Connecticut sales tax as manufacturing machinery?
It depends on how the software is bought. A manufacturer's CAD/CAM software that drives its computerized milling machines can qualify for a manufacturing exemption, but with a key catch: (1) if the so…
Is selling subscribers online access to a company's land-records database a taxable computer and data processing service in Connecticut?
Yes. A company that manually collects real-property transfer data from town records, loads it into its own daily-updated database, and sells subscribers 24-hour searchable access is rendering taxable …
Is a teleconferencing service provided by a company that isn't a telephone carrier a taxable telecommunications service in Connecticut?
No. A company that provides teleconferencing by bridging multiple phone calls through a computerized 'audio bridge' — while its own coordinators introduce, monitor, and manage the calls — is NOT rende…
Can a contractor that improves a government facility under an informal but binding agreement buy the incorporated materials free of Connecticut sales tax?
Yes. A limited partnership that operates a Connecticut political subdivision's facility and makes agency-funded improvements to it may purchase, free of sales and use tax, the materials and supplies t…
Is a company that supplies law-library staff and looseleaf filing to law firms providing taxable personnel services in Connecticut?
It splits. When the company supplies temporary LIBRARY PERSONNEL (librarians, paraprofessionals, clerks) to law firms, that IS a taxable personnel service under Conn. Gen. Stat. § 12-407(2)(i)(C): the…
Does air-control machinery in a manufacturer's clean room qualify for Connecticut's manufacturing-machinery sales and use tax exemption?
Yes. A company that makes hypodermic needles was building a 'clean room' — an enclosed, environmentally controlled space — and installing machinery to regulate the air's temperature, pressure, humidit…
Is customizing a customer's car with performance and body enhancements taxable in Connecticut as a repair, or as fabrication of the customer's property?
It's taxable, but as fabrication — not as a repair. A company added engine and body 'enhancements' (customization) to customers' vehicles, boosting their performance and value. DRS held this is NOT ta…
Does a Connecticut manufacturer owe use tax on product displays it buys, stocks with its goods, and gives free to retailers?
It depends on where the retailer is. A hardware maker bought empty product displays from an out-of-state supplier, stocked them with its hardware in Connecticut, and gave the stocked displays free to …
Is a company's on-line and archival data storage service a taxable computer and data processing service in Connecticut?
Partly. A division of a large out-of-state corporation stored Connecticut customers' data at out-of-state facilities, both on-line (customers access it from their own computers) and archival (data cop…
Is a crane or hydraulic excavator mounted on a truck chassis exempt from Connecticut sales tax as a 'commercial truck'?
Only if it mainly hauls freight. A company sold and leased cranes and hydraulic excavators mounted on truck chassis, each rated over 26,000 pounds and highway-capable. DRS held such a vehicle is exemp…
Are business management services a Connecticut company sells to out-of-state clients taxable when the clients do no business in Connecticut?
No. A Connecticut-headquartered parent corporation's only business was providing 'business analysis, management, management consulting and public relations services' (Conn. Gen. Stat. § 12-407(2)(i)(J…
Is an auto-parts locator service that gives customers access to a maintained database a taxable computer and data processing service in Connecticut?
Yes. An out-of-state company ran an auto-parts locator that let Connecticut insurers and salvage yards find parts either by logging into the company's mainframe database or by calling an '800' line wh…
When a building is gutted to its outer walls, are the construction services taxable renovation or exempt new construction in Connecticut?
Mostly untaxed new construction -- with one taxable exception. A company kept only the exterior walls of a former warehouse and built a new gabled skylight roof (adding cubic footage), new interior wa…
Is a satellite farm-data subscription a taxable computer service, are its ad transmissions taxable, and who owes tax on the receiving equipment?
A company beamed around-the-clock farm-market data (grain/livestock quotes, weather, news) by satellite to subscribers using company-owned receiving equipment, and also let 'information providers' sen…
Is separately-stated labor to install a product excluded from Connecticut sales tax when the product is attached to real property?
It depends on the type of real property. A company sold mailboxes and offered separately-stated installation (sinking a post, attaching the box). Conn. Gen. Stat. § 12-407(8)(e) and (9)(e) exclude sep…
Is a medical-claims processing and collection service a taxable computer service or business management service in Connecticut?
Neither -- it's not taxable. A company processed, managed and collected doctors' and hospitals' insurance and Medicare/Medicaid claims, retaining a percentage of what it collected as its fee, and it g…
Are a management company's nutrition and food-service charges to a nursing home taxable business management services in Connecticut?
It depends on who eats the meal. A management company ran a nonprofit nursing home's food service -- buying food as the home's agent, preparing and delivering meals, cleaning kitchen equipment, and ca…
Does a Connecticut DRS Ruling stop being reliable when the underlying law or regulation changes, even without notice from the Department?
Yes -- automatically. DRS held that one of its Rulings ceases to have any force and effect once the law or regulation it was based on changes, as of the effective date of that change and without any f…
When were a sales agent's fees subject to Connecticut sales tax on the sale of a business's tangible property?
Only in narrow circumstances -- and this ruling is now obsolete. A company introduced buyers and sellers of businesses and business assets for a contingent fee, without negotiating the deals. DRS held…
Are an out-of-state software company's analysis, adaptation, training, and license fees taxable in Connecticut?
It splits. An out-of-state company sold a tool for developing custom software -- analyzing each customer's needs, adapting the program, licensing it, and offering maintenance and training. DRS held th…
Is encoding machinery a satellite broadcaster uses to make its own broadcast disks exempt Connecticut manufacturing machinery?
No -- it's taxable. A satellite broadcaster ran about 80 channels from a Connecticut facility. To beam a movie, it first used high-speed 'encoding' machinery to convert the movie from analog videotape…
How are hazardous-waste cleanup, remediation, and related site services taxed under Connecticut's services-to-real-property tax?
It splits several ways. A company cleaned up hazardous waste at industrial and commercial sites -- decontaminating facilities and running groundwater/soil remediation. Connecticut taxes services to in…
Are environmental and safety training and consulting services for a manufacturer taxable business management services in Connecticut?
It depends on whether it's training or consulting. A manufacturer that generates hazardous waste hired a provider for a mix of environmental and safety services. DRS split them under the business-mana…
Are a town's 'pay-as-you-throw' trash-bag fees a taxable sale of bags or a nontaxable intangible right to dispose of trash?
Not taxable to residents. A Connecticut town ran a 'pay-as-you-throw' program: residents' trash is collected only if placed in special town bags, distributed (at town hall or through retail-store agen…
Are wigs and hairpieces for disease-related hair loss exempt from Connecticut sales tax as prostheses?
No -- and note this ruling is OBSOLETE: DRS marks it 'not current … reference purposes only' and states it was 'obsoleted by AN 94(5),' so do not rely on it. As issued, DRS held that wigs and hairpiec…
Are a meat packer's feed, hay, and packaging materials exempt from Connecticut tax as materials used in fabrication?
Mostly no. A Connecticut meat-packing plant bought live horses, slaughtered and butchered them, and packaged the meat (mostly for export to Europe). DRS held that the butchering and cutting of carcass…
Which parts of a gas pipeline are tax-exempt 'materials used directly in the furnishing of gas,' and is building the pipeline a taxable service?
Partly exempt. An interstate gas-pipeline company bought the components of a new Connecticut pipeline. DRS split them: the PIPE and the VALVE ASSEMBLIES and CONNECTORS are 'materials used directly in …
Is managing the redevelopment of a vacant office complex into a leased multi-tenant property a taxable service in Connecticut?
Yes, taxable. A property-management company was hired to oversee turning a vacant office complex into a fully occupied, multi-tenant property -- developing a master plan, hiring the architect and cont…
Are an investment advisory firm's consulting fees subject to Connecticut sales tax, and does it matter whose investments the advice concerns?
It depends on whose investments the advice is really about. An investment advisory company asked whether its investment-consulting fees are subject to Connecticut sales and use tax. DRS held: (a) NOT …
Are meals a charity buys to honor its volunteers exempt from Connecticut sales tax if the charity pays and takes no reimbursement?
Exempt. A charitable organization with a Connecticut exemption permit held an annual luncheon to honor and encourage its fundraising volunteers, paying entirely with its own funds by check and neither…
Is a members-only store's membership fee a nontaxable intangible right, or a taxable sale of the membership badge?
Not taxable. A members-only retail/wholesale store charged an annual membership fee for a badge that lets members enter the store and buy merchandise (the fee isn't credited toward purchases). DRS rul…
Is a company that only delivers other businesses' advertising -- without creating it -- providing a taxable advertising or public relations service?
Not taxable. A company delivered sponsors' advertising directly to households (people who had moved, newly engaged women, new parents, new U.S. citizens) -- presenting sales messages, imprinted advert…
Which direct-mail-firm charges are taxable in Connecticut -- the mailing service, the advertising, the printing, or the postage?
It depends on what the firm actually does. DRS addressed a direct mail firm in two situations. (a) PURE MAILING -- just sorting, folding, inserting, and mailing materials the client had printed elsewh…
Is selling advertising space in a periodically distributed trade directory taxable, or is it exempt 'media advertising'?
Exempt. A company published an annual directory of trade vendors (supplies and services for architects and contractors) and sold advertising space in it to those vendors, distributing the directory to…
Is delivering video programming to consumers by microwave or satellite a 'community antenna television service' subject to Connecticut sales tax?
Yes -- it is a 'community antenna television' (CATV) service. A company delivered video programming directly to consumers by microwave or satellite, with customers using descrambling equipment. DRS ru…
Does incorporating a farm void the individual farmer's tax exemption permit, and can the new corporation use the farmer's sales history to qualify?
Two traps. A farmer with a Connecticut Farmer Tax Exemption Permit planned to transfer his farm to a newly formed corporation in exchange for its stock. DRS ruled: (1) the transfer makes the farmer's …
Is a company that copies and sells certified hospital medical records selling taxable tangible personal property or an exempt service?
Taxable. A company copied certified hospital medical records and sold the copies to attorneys, insurers, peer-review organizations, government agencies, and individuals. DRS ruled this is a taxable SA…
Are charges for placing advertisements on the sides of trailer-trucks subject to Connecticut sales tax as advertising services?
Not taxable -- it counts as media advertising. A company charged for placing advertisements on the sides of its trailer-trucks. Connecticut taxes advertising services only when they are NOT related to…
Are a tax preparer's charges subject to Connecticut sales tax when it electronically files a client's return at no extra charge, even if the invoice does not separately state an e-filing charge?
Not taxable, on these facts. Electronic filing of a tax return is a taxable computer and data processing (CDP) service in Connecticut (Conn. Gen. Stat. § 12-407(2)(i)(A); TSSN-41), and when a preparer…
Is a company's survey research sampling service subject to Connecticut sales and use tax?
No -- not taxable. A company sold survey research sampling services: it drew random statistical samples from the demographic groups and geographic regions its clients specified (built from telephone l…
Is a service that retrieves motor vehicle records for customers -- using computers to match and transmit the data -- a taxable computer and data processing service in Connecticut?
Not a taxable computer service. A company retrieved motor vehicle driving records for its customers: it routed each request through a service bureau to the Connecticut DMV and returned the DMV's repor…
Is retipping a manufacturer's worn carbide saw blades a taxable repair service, or an exempt purchase of manufacturing tools?
Repair is taxable; a new blade is exempt -- but note this ruling is marked not current (obsoleted in part by AN 2000(8), clarified by Ruling 94-4), so confirm today's law. A kitchen-cabinet manufactur…
Are sales of surgical instruments and wound-closure supplies to doctors and veterinarians subject to Connecticut sales and use tax?
Taxable to doctors and vets; exempt only to nonprofit hospitals. A company sold surgical instruments and wound-closure supplies (staplers, clips, staples, suture materials, laparoscopic instruments). …
Were a nonprofit hospital's human-relations and organizational consulting services subject to Connecticut sales and use tax?
No under this historical ruling. A nonprofit charitable hospital's division advised public, private, and nonprofit organizations on workplace stress, wellness, morale, motivation, collaboration, commu…
May a Connecticut manufacturer buy air compressors tax-free when they eject parts from dies, sandblast finished products, and also power production machinery?
Yes, assuming the company qualified as a manufacturer. A compressor used to blow a part from a die and two compressors used primarily to sandblast parts in the final finishing stage qualified as machi…
Is on-site labor to relocate and install production machinery at a Connecticut customer's plant subject to sales tax?
No, if the installation labor is separately stated on the customer's bill. The trucking, hauling, crane, and rigging company removed and relocated floor lags, installed production machines on them, an…
Was hazardous-waste cleanup performed under a state environmental mandate considered 'voluntary' and excluded from Connecticut sales tax?
No under this historical ruling. The exclusion in Conn. Gen. Stat. § 12-407(2)(i)(I) applied only when a company acted solely on its own initiative. Cleanup following a federal or state agency mandate…
Were literary-agent fees taxable Connecticut sales-agent services when agents helped authors place manuscripts with publishers?
No. Literary agents represented authors in approaching publishers and were paid through retainers or commissions, but the manuscript was the author's intellectual product and was not tangible personal…
Browse Connecticut rulings by topic
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.