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Ezel / Tax Rulings / CT
CT Ruling 89-189 Sales and Use Taxes 1989-10-31

Were architects' feasibility studies evaluating whether office space met a client's needs subject to Connecticut sales and use tax?

Short answer: Yes under this historical ruling. Studies evaluating whether office space had enough room for personnel, equipment, and expected growth were taxable building planning or design services. DRS says AN 94(3) 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 reflecting the architectural-service rules then in effect. DRS expressly says Announcement (AN) 94(3) obsoleted it. Its result was limited to architect-performed office-space feasibility studies evaluating personnel, equipment, and growth needs and should not be assumed current. 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 -- obsolete historical guidance. DRS states that Announcement (AN) 94(3) obsoleted this ruling.

Plain-English summary

Architects evaluated whether particular office space could accommodate a client's personnel, equipment, and expected growth and gave an opinion on whether the space met the client's expectations.

DRS classified those feasibility studies as taxable building planning or design services.

What this means for you

The historical ruling treated this functional office-space evaluation as taxable architectural planning or design. AN 94(3) later obsoleted the guidance.

Common questions

Were the feasibility studies taxable? Yes under the ruling.

What did the architects evaluate? Space for personnel, equipment, and expected growth.

How did DRS classify the studies? As building planning or design services.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-189, Architectural Services

Ruling 89-189

Architectural Services

This Ruling has been obsoleted by   AN 94(3)

You have asked for a ruling on the sales and use tax consequences of certain feasibility studies performed by architects.

The specific type of feasibility study in question is a study where architects determine if a particular office space will accommodate their client. Typical client concerns include whether there is sufficient space for personnel, equipment and expected growth. The architect evaluates the office space in light of the client's needs and renders his opinion as to whether the space meets the client's expectation.

Section 12-407(2)(i)(F) imposes the sales and use tax on "architectural, building engineering and building planning or design services, including interior design and decorating services." It is our opinion that feasibility studies rendered by architects concerning office space are taxable as "building planning or design services."

LEGAL DIVISION

October 31, 1989

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