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Ezel / Tax Rulings / CT
CT Ruling 89-120 Sales and Use Taxes 1989-09-26

Did electricity used by an ice manufacturer qualify for Connecticut's manufacturing utility exemption?

Short answer: Yes, when at least 75% of the electricity was consumed in fabricating the ice sold. The exemption applied only to electricity, not other purchases. DRS says PS 94(3) superseded the ruling.

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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 reflecting the manufacturing electricity exemption then in effect. DRS expressly marks the information 'not current' and says Policy Statement (PS) 94(3) superseded it. The result depends on at least 75% fabrication use, and the ruling limits its conclusion to electricity rather than other purchases. 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)

Note -- superseded historical guidance. DRS marks this information "not current" and states that Policy Statement (PS) 94(3) superseded the ruling.

Plain-English summary

Electricity used by an ice manufacturer in actually fabricating the product sold was exempt when at least 75% of the electricity was consumed in fabrication.

The ruling stated that the exemption applied only to electricity and did not affect sales tax on other purchases.

What this means for you

The historical exemption depended on the 75% fabrication threshold and did not extend to non-electricity purchases. PS 94(3) later superseded it.

Common questions

What percentage was required? At least 75% fabrication use.

Did the ruling exempt other purchases? No.

Citations and references

  • Policy Statement (PS) 94(3) -- identified by DRS as superseding the ruling.

Source

Original ruling text

Ruling 89-120, Utility Exemption - Manufacturing

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

This Ruling has been superseded by PS 94(3)

The sale of electricity to an ice manufacturer for use in the actual fabrication of the product to be sold is exempt from sales and use tax when 75% or more of the electricity is consumed in the fabrication process.

This exemption pertains solely to the sale of electricity and has no bearing to the sales tax applicable to other purchases.

LEGAL DIVISION

September 26, 1989

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