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Ezel / Tax Rulings / CT
CT Ruling 89-115 Sales and Use Taxes 1989-09-26

How did Connecticut Ruling 89-115 tax copywriting, media advertising, collateral materials, and public-relations services?

Short answer: Copywriting for media advertising or incorporation into collateral items was not taxable, and the total price of media advertising was not taxable. Total receipts for collateral items and public-relations services were taxable.

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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 distinguishing copywriting and media advertising from collateral-item and public-relations receipts under the law then in effect. Later changes or different transaction structures may produce a different result. 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

Copywriting services supplied to advertising agencies for media advertising, or for incorporation into collateral items, were not taxable. The total sales price of media advertising was also not taxable.

The total gross receipts for collateral items such as pamphlets, brochures, sales literature, and direct mailers were taxable. Total receipts for public-relations services, including press releases, were also taxable.

What this means for you

The ruling separated the copywriting service from the taxable total receipts for finished collateral items. It also treated media advertising differently from public-relations services.

Common questions

Was copywriting for an advertising agency taxable? No, when used for media advertising or incorporated into collateral items.

Were brochures and direct mailers taxable? Yes. The ruling taxed total gross receipts for those collateral items.

Was media advertising taxable? No, according to the ruling.

Were public-relations services taxable? Yes, including the example of press releases.

Source

Original ruling text

Ruling 89-115, Tangible Property

Copywriting services rendered to advertising agencies for media advertising or incorporated into collateral items are not taxable. The total gross receipts for collateral items, such as pamphlets, brochures, sales literature, direct mailers, etc., are subject to the sales or use tax. The total sales price for media advertising is not subject to sales and use tax.

The total gross receipts for public relations services, e.g., press releases, are subject to the sales and use tax.

LEGAL DIVISION

September 26, 1989

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