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Ezel / Tax Rulings / CT
CT Ruling 90-4 Sales and Use Taxes 1990-01-11

Which guest-use and instruction charges at a member-owned private country club were excluded from sales and use tax?

Short answer: Under this historical ruling, guest golf, swimming, paddle-tennis, tennis, beach-club, and shooting-club fees were not subject to sales and use tax. Golf, swimming, paddle-tennis, and tennis lessons for members and guests, plus guest and member bowling fees, were also excluded. Club dues and initiation fees remained subject to the separate Section 12-543 tax. DRS says AN 95(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 confirming Revised Special Notice LSN-90 for a member-owned private country club under the club-dues and sales-tax rules then in effect. DRS says Announcement (AN) 95(3) obsoleted it. Its listed fee exclusions should not be assumed current or applied to different club ownership or 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 -- obsolete historical guidance. DRS states that this ruling was obsoleted by Announcement (AN) 95(3).

Plain-English summary

The ruling concerned a private country club owned and operated by its members. Its dues and initiation fees were subject to the historical tax under Conn. Gen. Stat. § 12-543.

DRS confirmed that the following separate charges were not subject to sales and use tax:

  • guest greens fees, swimming-pool fees, paddle-tennis fees, tennis fees, beach-club fees, and shooting-club fees;
  • golf, swimming, paddle-tennis, and tennis lessons or instruction for members and guests; and
  • guest and member bowling fees.

What this means for you

The historical ruling distinguished taxable club dues and initiation fees from the listed activity, guest, and instruction charges. AN 95(3) later obsoleted the guidance.

Common questions

Were dues exempt? No. The ruling states that dues and initiation fees were subject to tax under § 12-543.

Were guest tennis fees taxable? No under this ruling.

Were member bowling fees excluded too? Yes.

Citations and references

  • Conn. Gen. Stat. § 12-543.
  • Revised Special Notice LSN-90 (Rev. 12/89), as identified in the ruling.
  • Announcement (AN) 95(3) -- identified by DRS as obsoleting this ruling.

Source

Original ruling text

Ruling 90-4, Health and Athletic Clubs

Ruling 90-4

Health and Athletic Clubs

This Ruling has been obsoleted by   AN 95(3)

You seek confirmation of the Department's Revised Special Notice (LSN-90, Rev. 12/89) on the taxability of Health and Athletic Club Services as it pertains to a private country club.

With respect to a private country club owned and operated by the members where the dues and initiation fees are subject to tax under section 12-543 of the Connecticut General Statutes, the following charges are not subject to the sales and use tax:

  1. Guest greens fees (golf)

Golf lessons/instruction, driving range for members and their guests;

  1. Guest swimming pool fees

Lessons/instruction for members and their guests;

  1. Guest paddle tennis fees

Lessons/instruction for members and their guests;

  1. Guest tennis fees

Lessons/instruction for members and their guests;

  1. Guest and member bowling fees;

  2. Guest beach club fees; and

  3. Guest shooting club fees.

LEGAL DIVISION

January 11, 1990

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