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Ezel / Tax Rulings / CT
CT Ruling 89-177 Sales and Use Taxes 1989-10-30

Were power-line expansion design and small mobile control-building design subject to Connecticut sales and use tax?

Short answer: No under this historical ruling. Professional engineering for expansion of power-line systems was exempt, and design of small mobile control buildings that were easily disassembled was not treated as taxable building engineering. DRS says AN 94(3) partly obsoleted it.

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 engineering-service rules then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it in part. Its results were limited to power-line expansion and small mobile control buildings that were easily disassembled. 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 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 -- partially obsolete historical guidance. DRS marks this information "not current" and states that Announcement (AN) 94(3) obsoleted the ruling in part.

Plain-English summary

Professional engineering services designing expansion of power-line systems were exempt from sales and use tax under the cited statute.

DRS also did not treat design of small mobile control buildings as taxable building engineering when the structures were easily disassembled.

What this means for you

The historical ruling covered two specific engineering categories. AN 94(3) later obsoleted the guidance in part.

Common questions

Was power-line expansion engineering taxable? No under the ruling.

Was design of a small mobile control building taxable? No when the building was easily disassembled.

Citations and references

  • Conn. Gen. Stat. § 12-412(11), as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-177, Engineering

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

Ruling 89-177

Engineering

This Ruling has been obsoleted in part by   AN 94(3)

Professional engineering services that involve designing the expansion of power line systems are exempt from sales and use tax pursuant to section 12-412(11) of the Connecticut General Statutes.

This department does not regard the designing of structures by professional engineers that are mobile and easily disassembled as building engineering services. Therefore, the gross receipts for designing the small mobile control building are not subject to sales and use tax.

LEGAL DIVISION

October 30, 1989

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