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Ezel / Tax Rulings / CT
CT Ruling 89-202 Sales and Use Taxes 1989-11-08

Did a residence with an attached business office qualify for Connecticut's residential electricity exemption?

Short answer: Yes under this historical ruling if at least 51% of the entire building, including the residence and office, was occupied for residential dwelling purposes. DRS says Policy Statement 94(3) superseded the ruling.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 residential electricity exemption then in effect. DRS expressly says Policy Statement (PS) 94(3) superseded it. Its result depended on at least 51% of the combined residence-and-office building being occupied for residential dwelling purposes 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Note -- superseded historical guidance. DRS states that Policy Statement (PS) 94(3) superseded this ruling.

Plain-English summary

DRS said electricity sold to a building predominantly occupied for residential dwelling purposes was exempt from sales and use tax.

For a personal residence with an attached business office, the electricity purchase was exempt if at least 51% of the entire building, counting both the residence and office, was occupied for residential dwelling purposes.

What this means for you

The historical ruling used a whole-building majority-residential test. PS 94(3) later superseded the guidance.

Common questions

Did an attached business office automatically defeat the exemption? No.

What residential-use percentage was required? At least 51% of the entire building.

Was the office included in the measurement? Yes, along with the residence.

Citations and references

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

Source

Original ruling text

Ruling 89-202, Utility Exemption - Residential

Ruling 89-202

Utility Exemption - Residential

This Ruling has been superseded by   PS 94(3)

The sale of electricity to a building that is predominately occupied for residential dwelling purposes is exempt from sales and use tax.

Based on the information presented in your letter, your personal residence has a business office attached. Accordingly, if 51% or more of the building, inclusive of the residence and office, is occupied for residential dwelling purposes, then the purchase of electricity for said building is exempt from sales and use tax.

LEGAL DIVISION

November 8, 1989

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