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Ezel / Tax Rulings / CT
CT Ruling 89-63 Sales and Use Taxes 1989-08-22

Was electricity used for residential dwelling purposes in a condominium complex exempt under Connecticut Ruling 89-63?

Short answer: Yes. Electricity used in residential condominium units was exempt whether each unit was billed separately, rented to a residential tenant, or included in a single association bill for a predominantly residential complex. The ruling is superseded.

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 1989 Connecticut Department of Revenue Services Ruling is not current. The official page says it was superseded by Policy Statement 94(3), so it is provided only as historical reference and should not be used as current authority. It addressed electricity used for residential dwelling purposes in a described condominium complex under the law then in effect. 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 current treatment.
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

Electricity used for residential dwelling purposes in condominium units was exempt from sales or use tax under this ruling.

The described complex had 65 units, each separately billed by the electric company. The exemption applied to units used as the owners' residences and to units rented to tenants who occupied them as residential dwellings.

The ruling also said a single electric bill to a condominium association for the entire complex would be exempt if the complex was predominantly residential.

The official archive says this ruling was superseded by Policy Statement 94(3).

What this means for you

The historical ruling focused on how the electricity was used, not solely on whether the customer was an individual unit owner or the condominium association. Its superseded status means current eligibility must be verified separately.

Common questions

Were separately billed residential units exempt? Yes.

Did rented condominium units qualify? Yes, when tenants occupied them as residential dwellings.

Could an association-wide bill qualify? Yes, if it covered a predominantly residential condominium complex.

Citations and references

  • No statute or regulation was cited in the ruling text.

Source

Original ruling text

Ruling 89-63, Utility Exemption - Residential

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

Ruling 89-63

Utility Exemption - Residential

This Ruling has been superseded by  PS 94(3)

According to the information presented in your letter, there are sixty-five individual units in X Condominium Complex. Each of the sixty-five units is separately billed by the electric company for sales of electricity.

The sale of electricity for residential dwelling purposes is exempt from sales or use tax. When the utility company bills a condominium association for the electricity used by the entire complex, inclusive of all units contained therein, sales and use tax would not apply to the charges for electricity, providing the condominium complex is predominately residential.

In the situation described in your letter, each unit used for residential dwelling purposes is exempt from sales or use tax for purchases of electricity. The sales or use tax does not apply to sales of electricity used in condominium units that are rented to tenants who occupy the units as their residential dwellings.

LEGAL DIVISION

August 22, 1989

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