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Ezel / Tax Rulings / CT
CT Ruling 89-236 Sales and Use Taxes 1989-11-22

Were aircraft charter receipts, aircraft-sale brokerage fees, and aircraft-storage rentals subject to Connecticut sales and use tax?

Short answer: Charter receipts were taxable when a certificated carrier used in Connecticut an aircraft bought and held for resale, and brokerage fees were taxable for Connecticut aircraft sales. Aircraft-storage rental fees were not taxable. DRS says AN 2000(8) partly 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 aircraft rules then in effect. DRS expressly says Announcement (AN) 2000(8) obsoleted the ruling in part. Its charter result depended on a certificated carrier buying the aircraft for resale, holding it for resale, and using it in Connecticut; other facts were not addressed. 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 states that Announcement (AN) 2000(8) obsoleted this ruling in part.

Plain-English summary

When a certificated air carrier bought an aircraft for resale in its regular business, held it for resale, and used it for chartering, the full charter receipts were taxable if the aircraft was used in Connecticut.

Brokerage fees were taxable when the aircraft sales occurred in Connecticut. Rental fees for aircraft storage were not taxable.

What this means for you

The ruling drew different results for charter service, sale brokerage, and storage. AN 2000(8) later obsoleted part of the guidance, so the historical classifications should not be assumed current.

Common questions

Were aircraft charter receipts taxable? Yes under the described resale-and-charter facts when the aircraft was used in Connecticut.

Were aircraft-sale brokerage fees taxable? Yes when the aircraft sales occurred in Connecticut.

Were aircraft-storage rental fees taxable? No.

Citations and references

  • Announcement (AN) 2000(8) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 89-236, Aircraft

This Ruling has been obsoleted in part by AN 2000(8)

The total gross receipts for chartering aircraft are subject to sales and use tax when a certificated air carrier purchases an aircraft for resale in the regular course of business and uses said aircraft for chartering purposes while it is being held for resale. Accordingly, if the aircraft is used within this State, the gross receipts for the chartering service are taxable.

Brokerage fees are subject to sales and use tax when the sales of the aircraft occur in Connecticut.

Rental fees for the storage of aircraft are not subject to sales and use tax.

LEGAL DIVISION

November 22, 1989

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