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Ezel / Tax Rulings / CT
CT Ruling 89-276 Sales and Use Taxes 1989-12-13

Were engineering services for improvements and modifications to utilities' existing fuel systems taxable as building engineering or design?

Short answer: No under this historical ruling. A consulting engineer's designs for safe and reliable operation of local electric utilities' existing fuel systems or processes were not taxable building engineering or building planning/design services. DRS marks the ruling not current and obsoleted by AN 94(3).

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 classification then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 94(3) obsoleted it. Its treatment of utility fuel-system and process design should not be assumed current or applied to building-related engineering. 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 ruling "not current" and states that it was obsoleted by Announcement (AN) 94(3).

Plain-English summary

A consulting engineer designed system improvements and modifications for local electric utilities. The work supported safe and reliable operation of existing fuel systems or processes.

DRS ruled that those services were not taxable as building engineering or building planning/design under the historical provision.

What this means for you

The historical ruling classified engineering by what was designed. Improvements to existing utility fuel systems and processes were outside building engineering. AN 94(3) later obsoleted the guidance.

Common questions

Did the ruling cover building design? No. It addressed existing utility fuel systems or processes.

Were the described engineering fees taxable? No under the ruling.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(F), as amended by 1989 Conn. Pub. Acts 251.
  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 89-276, Engineering

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

Ruling 89-276

Engineering

This Ruling has been obsoleted by   AN 94(3)

As described in your letter, you are a consulting engineer who is commissioned by local electric utilities to design systems improvements and modifications for the safe and reliable operation of existing fuel systems or processes.

Your services are not subject to the sales and use tax as "building engineering and building planning or design services" under section 12-407(2)(i)(F) of the Connecticut General Statutes, as amended by Public Act No. 89-251.

LEGAL DIVISION

December 13, 1989

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