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Ezel / Tax Rulings / CT
CT Ruling 89-101 Sales and Use Taxes 1989-09-20

Were forensic-engineering investigations for insurance and legal clients taxable under Connecticut Ruling 89-101?

Short answer: No. Accident investigation, component-failure analysis, and fire-cause investigation were outside the cited categories for building engineering/design and business consulting or public relations. DRS says AN 94(3) partly obsoleted the ruling.

Apply this to your situation

This page answers the general question as of 1989. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1989
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official 1989 Connecticut Department of Revenue Services Ruling, but its page expressly says AN 94(3) obsoleted it in part. It is presented as historical reference, not as a complete statement of current forensic-engineering tax law. Connecticut imposes sales and use tax solely at the state level: there are no local or municipal sales taxes. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about current treatment.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

The described forensic-engineering services were not subject to sales and use tax.

The engineering firm investigated industrial and automotive accidents, component failures, and fire causes for insurance and legal clients. The clients used the work to evaluate insurance payments, address subrogation issues, and prepare legal briefs.

The ruling said these services did not fall within either cited taxable category: building engineering and building planning or design, or business analysis, management, consulting, and public-relations services.

The official page says AN 94(3) obsoleted the ruling in part.

What this means for you

The historical ruling distinguished investigative forensic engineering from building-design and business-consulting categories. Because DRS marks it partly obsolete, current forensic work requires current guidance.

Common questions

What forensic work did the ruling address? Industrial and automotive accident investigation, component-failure analysis, and fire-cause investigation.

Who used the services? Clients in the insurance and legal fields.

Were the services taxable? No under the ruling.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F) and (J), as amended by Public Act No. 89-251, as cited in the ruling.
  • AN 94(3), identified by the official page as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-101, Engineering

This Ruling has been obsoleted in part by AN 94(3)

You describe your business as "forensic engineering" whereby professional engineering investigation services are provided to clients in the insurance and legal fields. Your work involves, among other things, the investigation of both industrial and automotive accidents, failure analysis of components and the investigation of fire causes. Your services are utilized by your clients to determine the appropriateness of insurance payments, subrogation issues and the preparation of legal briefs.

It is our opinion that the services described herein are not subject to the sales and use tax. These services do not come within the scope of "building engineering and building planning or design services" pursuant to section 12-407(2)(i)(F) of the Connecticut General Statutes, as amended by Public Act No. 89-251, or within "business analysis, management, consulting and public relations services" pursuant to section 12-407(2)(i)(J) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

September 20, 1989

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