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Ezel / Tax Rulings / CT
CT Ruling 89-64 Sales and Use Taxes 1989-08-22

Which real-property inspection services were taxable under Connecticut Ruling 89-64?

Short answer: Inspections of existing commercial, industrial, or income-producing real property were taxable. Inspections of new construction and existing exclusively residential, owner-occupied one-, two-, or three-family property were not taxable. The ruling is partly obsolete.

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 fully current. The official page says it was obsoleted in part by Public Act 94-4, § 13 (May), with Special Notice 95(17) identified for reference. It is provided only as historical guidance and should not be used as current authority. 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

Inspection services for new construction were not taxable under this ruling. Inspection services for existing exclusively residential, owner-occupied one-, two-, or three-family real property were also not taxable.

By contrast, inspections of existing commercial, industrial, or income-producing real property were subject to sales and use tax.

The official archive says the ruling was obsoleted in part by Public Act 94-4, § 13 (May), and refers readers to Special Notice 95(17).

What this means for you

The historical classification depended on the property and whether it was new construction or existing property. Because the ruling is partly obsolete, its categories do not establish current tax treatment.

Common questions

Were new-construction inspections taxable? No, under this ruling.

What existing residential property qualified? Exclusively residential, owner-occupied one-, two-, or three-family real property.

Which existing properties were taxable? Commercial, industrial, or income-producing real property.

Citations and references

  • Public Act 94-4, § 13 (May), identified by the official page as partly obsoleting the ruling.
  • Special Notice 95(17), identified by the official page for reference.

Source

Original ruling text

Ruling 89-64, Inspection

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

Ruling 89-64

Inspection

This Ruling has been obsoleted in part by PA 94-4, 13 (May)  (see  SN 95(17) )

Inspection services rendered to new construction or existing one, two or three family exclusively residential, owner-occupied real property are not taxable.

Inspection services provided to existing commercial, industrial or income-producing real property are subject to the sales and use tax.

LEGAL DIVISION

August 22, 1989

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