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CT Ruling 89-220 Sales and Use Taxes 1989-11-15

Were fire-scene analysis services performed for insurance companies subject to Connecticut sales and use tax?

Short answer: No under this historical ruling. DRS said the described fire-scene analyst services—determining cause, insured involvement, documenting for possible subrogation, and reporting findings—were not taxable. DRS says Ruling 94-10 superseded it.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 service classification then in effect for the described fire-scene analyst. DRS expressly marks the information 'not current' and says Ruling 94-10 superseded it. Its conclusion should not be assumed current or extended beyond the listed insurance-company services. 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Note -- superseded historical guidance. DRS marks this information "not current" and states that Ruling 94-10 superseded this ruling.

Plain-English summary

Insurance companies hired the requester to determine a fire's cause and origin, decide whether the insured was involved, document the scene for possible subrogation, and provide a documented evaluation to the client.

DRS concluded that those fire-scene analyst services were not subject to sales and use tax.

What this means for you

The historical result was tied to the listed investigative and reporting services for insurers. Ruling 94-10 later superseded the guidance.

Common questions

Were the fire-scene analyst services taxable? No under the ruling.

What work did the analyst perform? Cause-and-origin analysis, assessment of insured involvement, scene documentation, and a written evaluation for the insurance-company client.

Citations and references

  • Ruling 94-10 -- identified by DRS as superseding this ruling.

Source

Original ruling text

Ruling 89-220, Consulting

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

Ruling 89-220

Consulting

This Ruling has been superseded by   Ruling 94-10

You state that you are hired by insurance companies to provide the following services:

Form an opinion of the cause and origin of a fire in order to determine whether the fire was accidental or intentional;

Determine if the insured is or is not involved in the causation of the fire;

Document the fire scene to preserve critical information should subrogation develop; and

Present client (usually insurance company) with a well documented evaluation of the cause and origin for the fire in question. This has become more necessary as the local and state fire Marshall's offices cut back their staff.

Based on the facts contained in your letter, it is the opinion of the Legal Division that your services as a "fire scene analyst" are not subject to the sales and use tax.

LEGAL DIVISION

November 15, 1989

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