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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Are subscriptions to an online learning platform taxable in Connecticut as digital goods, or as an enumerated training service?
The online learning plans are generally NOT taxable as digital goods, because their true object is a nontaxable education or training service, not the sale of an audio-visual product. But depending on…
Is the labor to install a fuel cell facility on real property a taxable service in Connecticut, or is it exempt as new construction / a site improvement?
The labor to install the fuel cell facility is a service to real property, not the installation of tangible personal property. And because the facility is a site improvement (construction of new real …
Is a Connecticut staffing company that employs healthcare workers and places them with client providers selling taxable personnel services?
Yes. Because the company employs the healthcare practitioners and the clients control what work they do and how, the true object is furnishing staff, so the charges are taxable personnel services unde…
In Connecticut, does a third-party food-delivery company have to charge sales tax on restaurant meals it resells, and is the delivery fee taxable?
The delivery company must charge sales tax on the meals it resells to customers and must include its delivery fee in the taxable price. Because the delivery company is reselling the meals, the restaur…
Is a transprostatic implant that corrects a urinary-tract deformity exempt from Connecticut sales tax as a correction for a functioning part of the body?
Yes. A permanent transprostatic implant that corrects a urinary-tract deformity is exempt from Connecticut sales tax under Conn. Gen. Stat. § 12-412(19)(C) as a correction or substitute for a function…
Are fees for premium content on restaurant table tablets taxable, is the vendor's device charge a taxable lease, and must the out-of-state vendor register in Connecticut?
Three yeses. Fees the restaurant charges customers for premium content (news, sports, games, music) on the table tablets are taxable computer and data processing services. The monthly fee the restaura…
Are spinal braces and cervical collars exempt from Connecticut sales tax when a medical provider customizes them for a specific patient?
Yes. Spinal orthotics such as back braces and cervical collars are exempt from Connecticut sales tax under Conn. Gen. Stat. § 12-412(19)(B) when a medical provider individually alters them (trimming, …
When are motor vehicle towing, transport, and roadside assistance services taxable in Connecticut, and can they be bought for resale?
It depends on how the vehicle is moved. Moving vehicles by automobile carrier truck (between lots or to auction) is not taxable, but moving them by wrecker or flatbed wrecker is taxable motor vehicle …
Is property management for a residential housing cooperative a taxable service to real property in Connecticut?
Yes. A residential housing cooperative is treated as income-producing real property -- the cooperative owns the property and members pay their share of its expenses as cooperative income -- so propert…
Are Connecticut sales and use taxes owed on a home warranty (home service contract), and does it matter whether the home is owner-occupied or a rental?
It depends on how the home is used. A home warranty on income-producing (rental) residential property is taxable on the entire contract price as a service to income-producing real property. On an owne…
Are orthodontists' clear aligners, protective gloves and masks, and give-away dental hygiene items subject to Connecticut sales and use tax?
It's a mix. Custom clear aligners are exempt as corrective equipment worn for a functioning part of the body under Conn. Gen. Stat. § 12-412(19)(C). The gloves and masks orthodontists and their staff …
Are herbal aloe beverages marketed with health claims taxable in Connecticut, or exempt as food products?
Exempt. The herbal aloe products — ready-to-drink, liquid concentrate, and powder-for-water — are exempt from Connecticut sales and use tax as food products for human consumption under Conn. Gen. Stat…
Are nutritional shakes, nutrition bars, and whole-food chewable tablets taxable in Connecticut, or exempt as food products?
Exempt. Powdered nutritional shake mixes and nutrition bars sold as snacks or meal substitutes, and chewable tablets and capsules made from powdered whole fruits, vegetables and grains, are all exempt…
Is a lab's testing of medical marijuana for safety and potency subject to Connecticut sales and use tax?
No. A lab's services testing medical marijuana for safety and potency are not subject to Connecticut sales and use tax, because testing services are not among the enumerated taxable services in Conn. …
Is a subscription fee for streaming or accessing digital content over the Internet subject to Connecticut sales and use tax?
Yes. A recurring subscription fee for streaming or otherwise accessing digital content over the Internet is subject to Connecticut sales and use tax when sold to a Connecticut customer, because provid…
Does a Connecticut store have to charge sales tax on bottled kombucha, or is it exempt as a food product?
No — kombucha is not exempt; it is taxable. Because kombucha is a carbonated beverage, it is excluded from Connecticut's sales-tax exemption for food products for human consumption under Conn. Gen. St…
Is a prescription cancer-treatment device that uses electric fields exempt from Connecticut sales and use tax?
Yes. Gross receipts from the retail sale of the Product — an FDA-approved, prescription-only device that uses alternating electric fields to treat glioblastoma (an aggressive brain cancer) — are exemp…
Which of an executive-search and leadership-consulting firm's services are subject to Connecticut sales and use tax?
It depends on the specific service. Executive and middle-management search are taxable employment-agency services, and most of the firm's assessment and consulting offerings — executive/board/cultural…
Does a homeowner owe Connecticut sales tax on propane bought to fuel a standby generator at home?
No. The sale of propane used to run a standby generator at a residential dwelling is exempt from Connecticut sales and use tax under Conn. Gen. Stat. § 12-412(3)(A), which exempts gas -- including bot…
Are copies of medical records taxable in Connecticut, and does it matter whether they're delivered on paper, by online access, by fax, or by email?
It depends on how the records are delivered. Paper (hard-copy) medical records sold by a records-retrieval vendor are taxable sales of tangible personal property, and giving Requesting Parties access …
Does a Connecticut photo booth business owe sales tax on the charge for a booth and attendant at a wedding or event?
Yes. A single, non-separately-stated charge for a photo booth and its attendant at an event is a taxable rental of tangible personal property under Conn. Gen. Stat. § 12-407(a)(2)(J). Because the even…
Is the electricity a wireless carrier uses at its Connecticut cell sites exempt as manufacturing utility use?
No. Electricity a wireless carrier uses at its Connecticut cell sites to transmit signals is not exempt under Conn. Gen. Stat. § 12-412(3)(A). That exemption covers electricity used directly to fabric…
Is leasing dark fiber taxed as a property lease and lit fiber as a telecommunications service in Connecticut?
Both are taxable, under different rules. Leasing 'dark fiber' -- the fiber-optic cable itself, without the equipment to light it -- is a taxable lease of tangible personal property under Conn. Gen. St…
When a power plant buys electricity, can it buy it tax-free — for resale, or as electricity used to generate its own electricity?
Partly yes. A Connecticut power producer may buy electricity tax-free for RESALE when it resells that power to wholesalers and distributors (Conn. Gen. Stat. § 12-410). It may also buy electricity exe…
Is the work of a consultant hired as an interim VP of sales and marketing -- recruiting reps, negotiating contracts, briefing the board, polishing sales materials -- taxable in Connecticut as a business consulting or advertising service?
Mostly taxable. A consultant hired as an interim VP of sales and marketing performed work that DRS treated as taxable business analysis, business management, business management consulting and busines…
When gas service is unbundled -- one company sells the gas and the local utility only transports it -- are the utility's transportation charges subject to Connecticut sales tax?
It depends on who is the retailer of the gas. Taxable 'delivery' charges (Conn. Gen. Stat. § 12-407(8)/(9)) are only those charged BY the retailer of the property. So when a gas marketer sells the gas…
When a company builds a power plant, can it buy the fuel and equipment tax-free -- fully as a utility 'furnishing electricity,' and partially as machinery used in 'processing'?
Both exemptions apply, at different levels. Generating electricity for sale counts as 'furnishing electricity' under Conn. Gen. Stat. § 12-412(18), so materials, tools and fuel used directly in genera…
Is professional 'proficiency testing' of Connecticut labs a taxable service, and does the out-of-state provider owe Connecticut use tax on the test materials it ships into the state?
Two answers. The proficiency-testing service itself is NOT taxable: though it looks like taxable 'business analysis,' it's excluded because it is performed by a profession (pathologists) under the pro…
Are rented uniforms and 'lab coats' costing less than $50 exempt from Connecticut sales tax, or are they taxable 'protective' clothing?
Exempt. Rented uniforms and 'lab coats' that cost less than $50 each and simply identify employees or protect against soil and stain are exempt articles of clothing under Conn. Gen. Stat. § 12-412(47)…
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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.