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 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…
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…
Can an asphalt-making paving contractor qualify for the manufacturing machinery exemption by splitting its paving jobs into separate contracts for the asphalt and the installation?
No. An asphalt-making paving contractor cannot qualify for the manufacturing machinery exemption (Conn. Gen. Stat. § 12-412(34)) by splitting its paving jobs into separate contracts for the asphalt an…
Are packet data-transmission offerings (X.25 and Frame Relay) taxable as telecommunications services or as computer and data processing services in Connecticut, and can the underlying telecom services be bought for resale?
They are taxed differently. The company's Frame Relay Service is a telecommunications service, taxable at 6%, and the telecommunications services the company buys to provide it CAN be purchased for re…
Does a pathology-testing company that analyzes patient specimens for physicians qualify for Connecticut's biotechnology sales-and-use-tax exemption on its purchases?
No. A company that performs pathology testing on patient specimens to help physicians diagnose, prognose, or monitor disease does not qualify for Connecticut's biotechnology exemption in Conn. Gen. St…
Which of a health-care management company's many services -- managed care advice, credentialing, quality assurance, claims processing, member services, contract, pre-certification, and utilization review -- are taxable in Connecticut, and under which service category?
It's service-by-service. DRS classified each service a health-care management company sells against Conn. Gen. Stat. § 12-407(2)(i)(J). Because the customers' core business is providing health care, s…
Are a company's computer-link services -- routing credit-card authorizations between merchants and card issuers, and connecting PC users to Internet service providers -- taxable Connecticut computer and data processing services?
Yes, both are taxable. A company that uses computers to link merchants' card-authorization devices to card-issuing banks, and to link PC users to an Internet/computer service provider, is providing ta…
Are satellite-based data communications services (monitoring pipelines, messaging trucks, sending distress signals, tracking cargo) taxed in Connecticut as telecommunications services, or as computer and data processing services?
It turns on the label, and it's still taxable either way the company hoped to avoid. Connecticut's satellite-based data communications service is NOT taxable as a telecommunications service under Conn…
When a company sells online access to the Connecticut DMV computer plus the software to use it, which parts are taxable — the online access, the software fee, the support, and the revenue-share payments?
It splits four ways. (1) The online service giving customers direct access to the DMV computer — to file registrations and make inquiries — IS taxable computer and data processing service under Conn. …
Is a phone-based auto-parts locating service — where employees use a computerized directory but do the finding by telephone — a taxable computer and data processing service in Connecticut?
No. A telephone auto-parts locating service is NOT a taxable computer and data processing service under Conn. Gen. Stat. § 12-407(2)(i)(A). Applying the 'true object' test, DRS found the computer here…
Is a 'phone flea market' — where sellers pay to be listed and buyers call in for the listings — a taxable sales-agent service or a taxable advertising service in Connecticut?
Neither — but this ruling is dated and only partly good law. As DRS decided it in 1994, a 'phone flea market' (sellers pay a flat fee to be listed; buyers call in for the listings and deal directly wi…
Is document scanning and indexing a taxable computer and data processing service in Connecticut, and is supervising a customer's own scanning staff taxable business management?
Document imaging is taxable; supervising the customer's staff is not. Scanning paper documents into electronic images and indexing them IS a taxable computer and data processing service under Conn. Ge…
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…
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 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…
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…
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 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 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…
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 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 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…
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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.