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Ezel / Tax Rulings / CT
CT Ruling 90-14 Sales and Use Taxes 1990-02-05

Were guest greens fees, tennis-court fees, club-professional services, and the professional's property sales or leases taxable?

Short answer: Under this historical ruling, a country club's greens fees and court-time fees charged to members' guests were not taxable, and club-professional services were exempt. But tangible personal property sold or leased by club professionals was taxable. DRS marks the ruling not current and obsoleted in part by AN 95(3).

Apply this to your situation

This page answers the general question as of 1990. Ezel answers yours, under current Connecticut tax law, with citations.

Currency note: this ruling is from 1990
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 1990 Connecticut Department of Revenue Services Ruling reflecting the country-club fee and professional-service rules then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 95(3) obsoleted it in part. Its treatment of guest fees, professional services, and property transactions should not be assumed current or applied to different club charges. 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 situation.
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)

Note -- partly obsolete historical guidance. DRS marks this ruling "not current" and states that it was obsoleted in part by Announcement (AN) 95(3).

Plain-English summary

DRS ruled that greens fees and court-time fees a country club charged to members' guests for using its golf course or tennis courts were not subject to sales and use tax.

Services performed by club professionals were also exempt under the cited historical statute.

The exemption did not extend to property transactions. Sales or leases of tangible personal property by club professionals were taxable.

What this means for you

The historical ruling separated access and professional-service charges from sales or rentals of physical property. Because AN 95(3) later obsoleted the ruling in part, current club charges must be classified under current law.

Common questions

Were guest greens fees taxable? No under the ruling.

Were a club professional's services exempt? Yes under Conn. Gen. Stat. § 12-412(11).

What did club professionals still have to tax? Their sales and leases of tangible personal property.

Citations and references

  • Conn. Gen. Stat. § 12-412(11).
  • Announcement (AN) 95(3) -- identified by DRS as partly obsoleting this ruling.

Source

Original ruling text

Ruling 90-14, Health Clubs

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

Ruling 90-14

Health Clubs

This Ruling has been obsoleted in part by   AN 95(3)

The greens fees or the court time fees that the country club charges the member's guests for use of the golf courses or tennis courts are not subject to sales and use tax.

The services of club professionals are exempt from the sales and use tax pursuant to Connecticut General Statute §12-412(11). However, the sales and/or leases of tangible personal property by club professionals are subject to the sales and use tax.

LEGAL DIVISION

February 5, 1990

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