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 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 …
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 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…
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…
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…
Did an out-of-state manufacturer become subject to Connecticut corporation business tax by leasing promotional video machines to Connecticut retailers?
Yes. The machines' advertising, order-form, and out-of-state order-solicitation functions were protected solicitation-related activities under Public Law 86-272, and unrelated contractors' repair visi…
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…
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…
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…
Were asbestos-removal services and the tangible property used to perform them subject to sales and use tax?
Under this historical ruling, asbestos-removal services were excluded as voluntary hazardous-waste containment or removal. Tangible personal property bought to perform those services remained taxable.…
Did a photocopying machine qualify for Connecticut's machinery sales-tax exemption under Conn. Gen. Stat. § 12-412(18)?
No under this historical ruling. DRS said a photocopying machine was not exempt because copying printed pages was not considered manufacturing or fabricating an item of tangible personal property.
Were X-ray or chemical inspection services taxable when performed on real property or tangible personal property?
Inspections of industrial, commercial, or income-producing real property were taxable except for new construction, while inspections of tangible personal property were not taxable. DRS marks the guida…
Were sales, leases, or rentals transferring dominion and control of computer software subject to Connecticut sales and use tax?
Yes under this historical ruling. DRS treated software as tangible personal property, included leasing within sales, and said transferring dominion and control was a taxable lease or rental rather tha…
Was the standalone creation of a freelance article taxable as consulting, public relations, advertising, or tangible personal property?
No under this historical ruling. Article creation without placement or dissemination involvement was not consulting or public relations, and the article was not taxable tangible personal property. The…
Were jewelry appraisals, jewelry or clock repairs, and engraving services taxable under Connecticut Ruling 89-140?
Jewelry appraisals were nontaxable. Jewelry and clock repair labor and parts were taxable. Engraving was taxable when part of a property sale but nontaxable when performed on customer-owned property. …
Were media-advertising receipts, including placement fees and development charges, subject to Connecticut sales and use tax?
No. Total receipts for media-advertising services, including placement and development charges, were nontaxable. The agency was the consumer of incorporated graphic designs, artwork, and mechanicals a…
How did Connecticut Ruling 89-119 distinguish exempt taxidermy services from taxable property sales?
Stuffing, preparing, and mounting customer-furnished animal remains were exempt services, with the taxidermist treated as consumer of supplies. Sales of skins, heads, mountings, or other tangible prop…
How did Connecticut Ruling 89-103 tax graphic design for media advertising and for incorporation into printed materials?
Graphic-design receipts were taxable when supplied to advertising agencies for media advertising and when incorporated into brochures and other tangible items. Agency fees for media advertising were n…
Were firearm sales subject to Connecticut sales tax under Ruling 89-96, or did the right to bear arms prevent the tax?
Firearm sales were taxable because firearms were tangible personal property and no stated exemption applied. The ruling also concluded that imposing sales tax on firearms did not tax or infringe the c…
Were testing or inspection services performed on tangible personal property taxable under Connecticut Ruling 89-66?
No. The ruling said testing or inspection services rendered to tangible personal property were not subject to Connecticut sales or use tax.
Who had to pay or collect Connecticut use tax on pads delivered by an out-of-state seller under Ruling 89-62?
The Connecticut purchaser owed the tax. If the out-of-state seller met Public Act 89-41's registration requirement, it had to register, collect, and bill the tax; otherwise, if it did not register, th…
How did Connecticut Ruling 89-42 tax systems-design training provided to individuals and businesses?
Training provided to individuals was not taxable if it was not connected with a sale of tangible personal property. The same systems-design training provided to businesses was subject to sales or use …
Were appliance-repair services billed to a manufacturer under its warranty taxable after July 1, 1989 under Connecticut Ruling 89-22?
Yes. Repair and maintenance services performed on or after July 1, 1989 on tangible personal property, including appliances, were taxable. The official page marks the ruling obsolete and says the rema…
Does the published text of Connecticut Ruling 91-21 decide how 900 Commercial Service charges are taxed?
No conclusion is published. The official page describes a carrier's 900 Commercial Service and six sponsor offerings, but it contains no tax question, analysis, holding, or issue date.
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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.