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Ezel / Tax Rulings / CT
CT Ruling 89-114 Sales and Use Taxes 1989-09-26

How did Connecticut Ruling 89-114 tax sheet-metal contractors' materials, HVAC installation labor, repairs, and resale-certificate work?

Short answer: Contractors paid tax on consumed materials. Installation labor was exempt for new construction and qualifying owner-occupied homes but taxable for existing commercial property; repair labor was taxable. DRS says AN 2000(8) 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 the information is not current and that AN 2000(8) obsoleted it in part. It is presented as historical reference, not as a complete statement of current contractor-tax law.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

Sheet-metal contractors paid sales and use tax on materials they consumed while performing ductwork on residential or commercial real property.

Labor for installing air-conditioning or heating systems was not taxable when performed for new construction or existing one-, two-, or three-family homes that were exclusively residential and owner-occupied. Installation labor for existing commercial, industrial, or income-producing property was taxable.

Labor for repairs to furnaces, oil burners, water heaters, air conditioners, and similar equipment was taxable in both residential and commercial realty. The ruling also allowed sheet-metal contractors to accept bona fide resale certificates from air-conditioning and heating contractors for services involving renovations of commercial, industrial, and income-producing property.

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

What this means for you

The historical ruling distinguished materials, installations, and repairs, and it varied installation treatment by the type and use of the property. Because DRS marks it partly obsolete, current contractor work requires current guidance.

Common questions

Did sheet-metal contractors pay tax on consumed materials? Yes.

Was HVAC installation labor taxable on new construction? No under the ruling.

Was installation labor taxable on existing commercial property? Yes.

Were furnace and air-conditioner repairs taxable? Yes, in residential and commercial realty.

Could a sheet-metal contractor accept a resale certificate? Yes, in the renovation circumstances described in the ruling, if the certificate was bona fide.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(I), as amended by Public Act No. 89-251, as cited in the ruling.
  • Reg. Conn. State Agencies § 12-426-1, as cited for resale certificates.
  • AN 2000(8), identified by the official page as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-114, Contractors

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

This Ruling has been obsoleted in part by AN 2000(8)

Sheet metal contractors pay sales and use tax for purchases of materials they consume in performing ductwork to residential or commercial real property under the old and new sales and use tax statutes.

The labor charges by sheet metal contractors for installations of air conditioners and/or heating systems provided to new construction or existing one, two or three family exclusively residential owner-occupied homes are not taxable. The labor charges by sheet metal contractors for installations of air conditioners and/or heating systems rendered to existing commercial, industrial or income-producing real property are subject to sales and use tax pursuant to section 12-407(2)(i)(I) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

Labor charges by sheet metal contractors for repairs rendered to furnaces, oil burners, water heaters, air conditioners, etc., performed in residential or commercial realty are subject to sales and use tax.

Sheet metal contractors may accept bona fide Resale Certificates pursuant to section 12-426-1 of the Regulations of Connecticut State Agencies issued by air conditioning and heating contractors for services rendered to renovations of commercial, industrial and income-producing real property.

LEGAL DIVISION

September 26, 1989

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