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Ezel / Tax Rulings / CT
CT Ruling 89-89 Sales and Use Taxes 1989-09-06

Did Connecticut Ruling 89-89 exempt electricity supplied through one meter to an apartment building used predominantly as residential dwellings?

Short answer: Yes. Electricity sold to the single-meter apartment building was exempt if the building and its electricity use were predominantly for residential dwelling purposes. DRS says PS 94(3) superseded the ruling.

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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Department of Revenue Services Ruling, but its page expressly says the information is not current and that PS 94(3) superseded the ruling. It is presented only as historical reference and should not be used as current law. 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 utility exemptions.
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 sold to an apartment building was exempt when the building was predominantly occupied for residential dwelling purposes.

The premises had a single electric meter. The ruling said the entire electric bill was nontaxable if the electricity used at the building was predominantly for residential dwelling purposes.

The official page says this information is not current and PS 94(3) superseded the ruling.

What this means for you

The historical ruling applied a predominant-use test to a single-meter apartment building. Because PS 94(3) superseded it, current mixed-use or multifamily utility treatment requires current guidance.

Common questions

Did one meter prevent the exemption? No.

What use had to predominate? Residential dwelling use of the building and its electricity.

Was the whole electric bill exempt under those facts? Yes.

Is this ruling current? No. PS 94(3) superseded it.

Citations and references

  • PS 94(3), identified by the official page as superseding this ruling.

Source

Original ruling text

Ruling 89-89, Utility Exemption - Residential

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

Ruling 89-89

Utility Exemption - Residential

This Ruling has been superseded by   PS 94(3)

The sale of electricity to an apartment building that is predominately occupied for residential dwelling purposes is exempt from sales and use tax.

According to the information presented in your letter, the premises are serviced by only one electric meter. If the electricity used at the apartment building is predominately for residential dwelling purposes, then the electric bills for the premises are not subject to sales and use tax.

LEGAL DIVISION

September 6, 1989

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