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Ezel / Tax Rulings / CT
CT Ruling 90-78 Sales and Use Taxes 1990-12-20

Were crane and rigging charges taxable when a company lifted structural building components or modular offices into place but did no connecting, disconnecting, or repair work?

Short answer: No. The company delivered, unloaded, placed, and removed air-conditioning compressors, trusses, headers, and relocatable modular office units, but did not connect or disconnect them or perform repairs. DRS held that the transportation, crane, and rigging work was not a taxable service to industrial, commercial, or income-producing property and was not a repair service when removal merely enabled an independent third party to repair the component.

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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 Ruling of the Connecticut Department of Revenue Services (DRS), typically issued to a specific taxpayer in response to that taxpayer's request and based on the specific facts presented and the Connecticut tax law in effect when it was issued. DRS may later declare a Ruling obsolete or supersede it by a subsequent Ruling, Policy Statement, or Announcement, so a taxpayer with different facts should not assume it still applies. Taxpayer-identifying details are redacted. Connecticut imposes its 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)

Plain-English summary

A crane company delivered, unloaded, placed, and removed structural components such as air-conditioning compressors, trusses, and headers at industrial or commercial properties. It also offloaded relocatable modular office buildings onto foundations or piers and loaded them for removal. The company did no connecting, disconnecting, or repair work.

DRS held that the crane and rigging charges were not subject to sales and use tax as services to industrial, commercial, or income-producing property. Removing a component so an independent third party could repair it also did not turn the crane company's work into a taxable repair service.

This ruling complements Ruling 90-79, issued the same day, which reached a similar result for moving nonstructural production machinery. In both, the crane company's limited role -- transport and placement without connection or repair -- controlled.

What this means for you

Crane work can remain a transportation/placement service even for structural components when the provider does not integrate them into the building or repair them. Added connection, disconnection, or trade work could change the result.

Common questions

Did placing an air-conditioning compressor make the work taxable? No on these facts, because the company did no connecting work.

Was removal for third-party repair taxable repair service? No. The crane company did not perform the repair.

Citations and references

  • Conn. Gen. Stat. § 12-407(8)(e).
  • Conn. Gen. Stat. § 12-407(2)(i)(I) and (Q).
  • Public Act 89-123.

Source

Original ruling text

Ruling 90-78, Crane and Rigging Services

Ruling 90-78

Crane and Rigging Services

FACTS:

Company's transportation, crane and rigging services include the delivery, unloading, setting in place and/or removal of structural components for industrial, commercial, or income-producing real property. For example, Company will provide a crane and operator to place an air conditioning compressor or other structural building component (i.e., trusses, headers, etc.) onto industrial, commercial, or income-producing real property. Company does not provide any connecting work or disconnecting work related to such structural components. Removal of such equipment by Company may be done to facilitate repair of the equipment by a third party. Company does not perform any repair services to the equipment.

Company also performs services for the manufacturers of relocatable modular office buildings. The manufacturer either leases or sells the units to the property owner. Company offloads the modular units from the manufacturer's trucks onto the foundation or piers with a crane and, when necessary, also loads them onto the manufacturer's trucks for transportation away from a site.

RULING:

Section 12-407(8)(e), as amended by Public Act 89-123, effective October 1, 1989 provides that the term "sales price" does not include the amount charged for labor rendered in installing or applying the property sold, provided such charge is separately stated and exclusive of such charge for any service rendered within the purview of subparagraph (I) of subdivision (i) of subsection (2) of Section 12-407 (i.e. services to industrial, commercial or income-producing property).

Company does not provide services related to connecting equipment or structural components which would cause it to become a part of the building or to disconnecting them. Therefore, Company's transportation, crane and rigging services are not subject to sales and use tax as a service to industrial, commercial or income-producing real property under Section 12-407(2)(i)(I) or as a repair service to tangible personal property under Section 12-407(2)(i)(Q) when the component if being removed by Company in connection with repair services to be performed by a third party.

LEGAL DIVISION

December 20, 1990

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