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Ezel / Tax Rulings / CT
CT Ruling 89-147 Sales Tax 1989-10-12

Did the described meat manufacturer qualify for Connecticut's sales-tax exemption on utility bills?

Short answer: Yes under this historical ruling. The business cut or reshaped raw product, heat-treated it, changed product characteristics with seasonings, and formulated sausages. DRS concluded that it qualified for the manufacturer's utility-bill exemption. DRS says PS 94(3) superseded the ruling.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 reflecting the manufacturing utility exemption then in effect. DRS expressly marks the information 'not current' and says Policy Statement (PS) 94(3) superseded it. The published text gives no percentage or other qualification test beyond the described meat-processing and sausage-manufacturing facts. Connecticut imposes sales 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 your specific situation.
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Note -- superseded historical guidance. DRS marks this information "not current" and states that Policy Statement (PS) 94(3) superseded the ruling.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

The business began with raw meat product, cut or reshaped it, heat-treated it, changed product characteristics by adding seasonings, and formulated sausages as value-added products.

After reviewing the submitted materials, DRS concluded that the business qualified for the manufacturer's exemption from sales tax on utility bills.

What this means for you

The brief historical ruling gives the result for the described meat manufacturer but does not state the exemption's percentage or other qualification test. PS 94(3) later superseded it.

Common questions

Did the business qualify for the utility-bill exemption? Yes.

What manufacturing activities did the ruling describe? Cutting or reshaping raw product, heat treatment, adding seasonings, and formulating sausages.

Citations and references

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

Source

Original ruling text

Ruling 89-147, Utility Exemption - Manufacturing

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

Ruling 89-147

Utility Exemption - Manufacturing

This Ruling has been superseded by  PS 94(3)

In your letter dated August 15, 1989 you state that as a meat manufacturer, you start with a raw product, cut or reshape it and then heat treat it and sell the product. In addition, you change the characteristics of a product by adding seasonings and you also formulate sausages, thereby manufacturing a value-added product.

The Legal Division has reviewed the materials submitted in support of your claim that X Company qualifies for the manufacturer's exemption from the sales tax on utility bills.

It is our opinion that your business qualifies for the exemption.

LEGAL DIVISION

October 12, 1989

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