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Ezel / Tax Rulings / CT
CT Ruling 89-94 Sales and Use Taxes 1989-09-08

Did Connecticut Ruling 89-94 include a lessee's property-tax reimbursement in the lessor's taxable gross receipts?

Short answer: Yes, generally. A lessor's gross receipts included all amounts paid by the lessee, including property-tax reimbursement. The ruling identified an exclusion only for property-tax reimbursement under a motor-vehicle lease.

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 applying the law then in effect to property-tax reimbursements paid under leases. Later changes in statutes, cases, or guidance may produce a different result, and another taxpayer should not assume this historical ruling controls a current lease. 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 lease.
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

A lessor's gross receipts generally included all amounts the lessee paid to the lessor, including reimbursement of property taxes.

The ruling identified one exception: property-tax reimbursement was excluded from gross receipts when a motor-vehicle lease was involved.

What this means for you

Under the historical rule, separately describing a lease payment as property-tax reimbursement did not remove it from the lessor's gross receipts unless the cited motor-vehicle lease exception applied.

Common questions

Were property-tax reimbursements generally included in lease gross receipts? Yes.

What exception did the ruling identify? Property-tax reimbursement under a motor-vehicle lease.

Citations and references

  • Conn. Gen. Stat. § 12-412(49), as cited in the ruling.
  • Geckle v. Dubno, 2 Conn. App. 303 (1984), cited by the ruling.

Source

Original ruling text

Ruling 89-94, Leasing

The General Assembly intended that a lessor's gross receipts include all amounts paid to the lessor by the lessee, including property tax reimbursement. See Geckle v. Dubno , 2 Conn. App. 303 (1984). It intended to exclude property tax reimbursement from a lessor's gross receipts only where a motor vehicle lease is involved. See Conn. Gen. Stat. §12-412(49).

LEGAL DIVISION

September 8, 1989

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