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Ezel / Tax Rulings / CT
CT Ruling 89-41 Real Estate Conveyance Tax 1989-08-14

How did Connecticut Ruling 89-41 determine the conveyance-tax rate for mixed-use property, and were realtor or appraisal services taxable consulting?

Short answer: The conveyance-tax rate for mixed residential and commercial property followed the property's predominant use. The cited taxable-service provision did not tax realtor services for selling, leasing, or renting real property or a realtor's real-estate appraisal services.

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 interpreting tax-law changes effective July 1, 1989 for mixed-use real estate conveyances and specified realtor and appraisal services. Later statutory or administrative changes may produce different results, and another seller or real-estate professional should not assume this historical ruling states current rates or service treatment. This summary is informational only and is not legal or tax advice. Consult a licensed Connecticut tax professional about a current conveyance or service.
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)

Plain-English summary

For property with mixed residential and commercial use, the real estate conveyance-tax rate was based on the property's predominant use.

The ruling also addressed the sales-tax category for business analysis, management, consulting, and public-relations services. It said that provision did not tax a realtor's services in selling, leasing, or renting real property, and did not include a realtor's real-estate appraisal services.

What this means for you

The historical ruling used one dominant-use classification for a mixed-use conveyance rather than separately assigning rates to the residential and commercial portions. It also kept the specified brokerage and appraisal work outside the cited taxable-service category.

Both holdings interpreted changes effective in 1989 and do not establish current rates or service classifications.

Common questions

How was mixed-use property classified for conveyance tax? By its predominant use.

Were realtor services for a sale, lease, or rental taxed under the cited consulting-services provision? No.

Were a realtor's real-estate appraisal services included? No.

Citations and references

  • Conn. Gen. Stat. § 12-407(2)(i)(J), as cited in the ruling.

Source

Original ruling text

Ruling 89-41, Real Estate Conveyance Tax

Ruling 89-41

Real Estate Conveyance Tax

This is in reply to your letter requesting interpretations of the new tax law effective July 1, 1989.

Your first question relates to changes made in the real estate conveyance tax. You inquire as to the proper rate of conveyance tax for property that has mixed residential and commercial use. Please be advised that the rate of taxation should be based on the predominant use of the property.

Your second question pertains to whether business analysis, management, consulting and public relations services (Conn. Gen. Stat. §12-407(2)(i)(J)) includes services rendered by real estate brokers, real estate salesmen and real estate appraisers in connection with the sale, lease, rental or appraisal of real property. Please be advised that the above-cited statutory section does not tax the services of a realtor on the sale, lease or rental of real property, nor does it include the services of a realtor who appraises real estate.

TIMOTHY F. BANNON
COMMISSIONER

August 14, 1989

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