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Ezel / Tax Rulings / CT
CT Ruling 89-203 Sales and Use Taxes 1989-11-08

Were process-engineering services for industrial environmental problems subject to Connecticut sales and use tax?

Short answer: No under this historical ruling. DRS said X Corporation's process-engineering services, including wastewater treatment and hazardous-waste management for industrial clients, were not taxable as building engineering or building planning and design. 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 engineering-service rules then in effect. DRS expressly marks the information 'not current' and says Announcement (AN) 94(3) obsoleted it. Its result was limited to the described process-engineering services for industrial environmental problems 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 marks this information "not current" and states that Announcement (AN) 94(3) obsoleted the ruling.

Plain-English summary

X was a process-engineering firm that helped industrial clients correct environmental problems, including through wastewater treatment and hazardous-waste management.

DRS concluded that those services were not taxable as building engineering or building planning and design services.

What this means for you

The historical ruling classified the described environmental process engineering separately from taxable building engineering. AN 94(3) later obsoleted the guidance.

Common questions

Were X Corporation's environmental process-engineering services taxable? No under the ruling.

What work did the ruling identify? Wastewater treatment and hazardous-waste management among a broader range of environmental services.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as cited in the ruling.
  • Public Act No. 89-251, as cited in the ruling.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-203, Engineering

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

Ruling 89-203

Engineering

This Ruling has been obsoleted by   AN 94(3)

X is a firm of process engineers specializing in correcting environmental problems for industrial clients by offering a broad range of environmental services including wastewater treatment and hazardous waste management.

It is our opinion that the services rendered by X Corporation are not subject to the sales and use tax under section 12-407(i)(2)(F) of the Connecticut General Statutes, as amended by Public Act No. 89-251, which taxes "building engineering and building planning or design services."

LEGAL DIVISION

November 8, 1989

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