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Ezel / Tax Rulings / CT
CT Ruling 89-102 Sales and Use Taxes 1989-09-22

Could a customer buy services to industrial, commercial, or income-producing real property tax-free for resale under Connecticut Ruling 89-102?

Short answer: Only if the purchasing company had a Connecticut seller's permit. The services could be resold, but a purchaser without the permit could not buy them tax-free on a resale basis. DRS says AN 2000(8) 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 the information is not current and that AN 2000(8) obsoleted the ruling. It is presented only as historical reference and should not be used as current law.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 resale requirements.
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

Services to industrial, commercial, or income-producing real property could be sold for resale under the ruling, but the purchasing company had to hold a seller's permit issued by the Department.

Without that permit, the purchaser could not buy the services tax-free on a resale basis.

The official page says this information is not current and that AN 2000(8) obsoleted the ruling.

What this means for you

The historical ruling did not treat a claimed resale as self-executing. The service purchaser needed the Department-issued seller's permit before buying the commercial-real-property services tax-free. Because the ruling is obsolete, current transactions require current guidance.

Common questions

Could the services be resold? Yes under the ruling.

Could any purchaser claim the resale treatment? No. The purchaser had to have a seller's permit.

What if the purchasing company had no permit? It could not buy the services tax-free for resale.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(I), as cited in the ruling.
  • AN 2000(8), identified by the official page as obsoleting this ruling.

Source

Original ruling text

Ruling 89-102, Resale

This information is not current and is being provided for reference purposes only

This Ruling has been obsoleted by AN 2000(8)

Your Company provides "services to industrial, commercial or income-producing real property" as defined in section 12-407(2)(i)(I) of the Connecticut General Statutes. While those services could be sold for resale, the company purchasing those services for resale would be required to have been issued a seller's permit by this Department. If no such permit has been issued to the purchasing company, it cannot purchase services to industrial, commercial or income-producing real property tax-free on a resale basis from your company.

LEGAL DIVISION

September 22, 1989

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