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Ezel / Tax Rulings / CT
CT Ruling 90-24 Sales and Use Taxes 1990-02-15

Were environmental-facility siting and remediation-design services taxable as building engineering or building design?

Short answer: Generally no under this historical ruling. DRS excluded siting and design of landfills, impoundments, hazardous-waste facilities and incinerators, plus groundwater cleanup and remedial-program design. But designing a building to house a hazardous-waste facility or incinerator was taxable. DRS says AN 94(3) obsoleted the ruling.

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 building-engineering and environmental-design rules then in effect. DRS expressly marks it 'not current' and says Announcement (AN) 94(3) obsoleted it. Its facility, remediation, and building-design distinctions should not be assumed current or applied to different work. 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 -- obsolete historical guidance. DRS marks this ruling "not current" and states that it was obsoleted by Announcement (AN) 94(3).

Plain-English summary

Connecticut's historical tax on building engineering and building planning or design did not apply to several environmental-engineering services:

  • locating and designing landfills, surface impoundments, hazardous-waste facilities, and incinerators;
  • recommending groundwater cleanup or site remediation; and
  • designing remediation programs involving groundwater recovery and treatment, slurry walls, groundwater diversion, or site sealing and capping.

DRS drew a different line for an actual building: fees for designing a building that housed a hazardous-waste facility or incinerator were taxable.

What this means for you

The historical ruling separated design of the environmental facility or remediation system from design of a building enclosing it. AN 94(3) later obsoleted that distinction as published guidance.

Common questions

Was landfill or incinerator design taxable as building engineering? No under the ruling.

What if the engineer designed a building for the facility? That building-design fee was taxable.

Were groundwater remediation plans included? Yes. The ruling lists cleanup recommendations and several remedial-system designs.

Citations and references

  • Announcement (AN) 94(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 90-24, Engineering

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

Ruling 90-24

Engineering

This Ruling has been obsoleted by   AN 94(3)

The Connecticut sales and use tax on "building engineering and building planning or design services" does not apply to the following services:

the location and design of landfills, surface impoundments, hazardous waste facilities, and incinerators; however, the design fees for a building to house hazardous waste facilities or incinerators would be subject to the sales tax;

recommendations for ground water cleanup or site remediation;

the design of remedial programs including ground water recovery and treatment, slurry wall construction, ground water diversion, and site sealing and capping.

James F. Meehan

Commissioner

February 15, 1990

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