When a hotel stay lasts more than 30 consecutive days, does Connecticut's room occupancy tax still apply to the first 30 days?

Note — obsolete guidance. DRS has obsoleted this Ruling (superseded by Announcement 94(8)), and the ruling itself carries DRS's banner that it "is not current and is being provided for reference purposes only." The summary below explains what Ruling 91-20 said when it was issued in 1991; it does not state Connecticut's current law on the room occupancy tax or how long-term stays are treated today. Do not rely on it — confirm the current rule with DRS.

Plain-English summary

A hotel agreed to rent a room to a guest for more than thirty consecutive days. It asked a narrow question: when a stay runs past thirty days, is the room occupancy tax owed on the charge for the first thirty-day period, or is the whole long stay treated as non-taxable?

In 1991, DRS answered that the first thirty days are taxable. Connecticut's tax works off a thirty-day line:

• A taxable "sale" of lodging is a transfer of occupancy for "thirty consecutive calendar days or less" (Conn. Gen. Stat. § 12-407(2)(h); the parallel "purchase" definition is in § 12-407(7)(a)).
• The tax is imposed (then at eight percent) on the rent "for the first period of not exceeding thirty consecutive calendar days" (Conn. Gen. Stat. § 12-408(1)).

DRS read the phrase "the first period of not exceeding thirty consecutive calendar days" to mean the tax applies to the first thirty days of a room's occupancy regardless of the fact that the stay may exceed thirty consecutive days. So the charge for the first thirty consecutive days was subject to the room occupancy tax, and the charge for occupancy after the first thirty consecutive days was not.

Because this Ruling has been obsoleted (see the note above), treat the mechanics below as history, not current law.

What this means for you

The 1991 rule: a long stay didn't erase tax on the first 30 days

Under this ruling, going past thirty days did not make the whole stay tax-free retroactively. The first thirty days were taxed; only the portion of the charge attributable to days after thirty was outside the tax.

This has been superseded — do not apply it today

The most important takeaway is the caveat. DRS obsoleted Ruling 91-20 through Announcement 94(8), and the state's own page flags it as not current. How Connecticut taxes extended hotel stays, and where the thirty-day line falls, should be checked against the current statute and DRS guidance — not this ruling.

If you run a hotel or extended-stay property, confirm the current rule

Because extended-stay billing depends on exactly this thirty-day question, and the guidance here is obsolete, verify the present treatment (and the current tax rate) with DRS before setting up how you charge and remit tax on long stays.

Common questions

Q: Can I rely on Ruling 91-20 today?
A: No. DRS has obsoleted it (superseded by Announcement 94(8)), and it is expressly marked "not current." It is provided for reference only. Confirm the current room occupancy tax rules with DRS.

Q: What did the ruling actually say back in 1991?
A: That the room occupancy tax applied to the charge for the first thirty consecutive days of a hotel stay even if the total stay was longer, and that the charge for occupancy after the first thirty days was not taxed.

Q: Where did that come from?
A: From Conn. Gen. Stat. § 12-408(1), which taxed rent "for the first period of not exceeding thirty consecutive calendar days," read together with the § 12-407(2)(h) definition of a taxable occupancy as one of thirty consecutive days or less.

Q: How are long-term hotel stays taxed now?
A: This page can't answer that from an obsolete ruling. The treatment of long-term stays has been revisited since 1991 — check the current statute and DRS guidance, or ask a Connecticut tax professional.

Citations and references

Statutes:

• Conn. Gen. Stat. § 12-407(2)(h) — a taxable "sale"/"selling" includes occupancy of a hotel/lodging-house room for thirty consecutive calendar days or less
• Conn. Gen. Stat. § 12-407(7)(a) — corresponding "purchase"/"purchasing" definition
• Conn. Gen. Stat. § 12-408(1) — imposed the tax (then 8%) on rent "for the first period of not exceeding thirty consecutive calendar days"

Status:

• Obsoleted by Announcement (AN) 94(8); DRS marks the ruling "not current … provided for reference purposes only."

Source

• Landing page: Connecticut DRS Rulings
• Ruling: Ruling 91-20

Original ruling text

Ruling 91-20, Room Occupancy Tax

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

Ruling 91-20

Room Occupancy Tax

This Ruling has been obsoleted by   AN 94(8)

FACTS:

Hotel agrees to provide lodging for a period of more than thirty consecutive days.

ISSUE:

Where the period of occupancy of a hotel room is in excess of thirty consecutive days, does the room occupancy tax apply to the charge attributable to the initial thirty-day period?

DISCUSSION:

Conn. Gen. Stat. §12-407(2)(h) defines the terms "sale" and "selling" to include "a transfer for a consideration of the occupancy of any room or rooms in a hotel or lodging house for a period of thirty consecutive calendar days or less ...." Conn. Gen. Stat. §12-407(7)(a) contains a corresponding definition of the terms "purchase" and "purchasing".

Conn. Gen. Stat. §12-408(1) imposes the sales tax on all persons operating a hotel or lodging house at the rate of eight percent of the gross receipts "with respect to each transfer of occupancy, from the total amount of rent received for such occupancy of any room or rooms in a hotel or lodging house for the first period of not exceeding thirty consecutive calendar days ...." [emphasis added]

The reference to "the first period of not exceeding thirty consecutive calendar days" indicates that the room occupancy tax applies to the first thirty days of occupancy of a room in a hotel or lodging house without regard to the fact that the occupancy may exceed a period of thirty consecutive days.

RULING:

The charge attributable to the first thirty consecutive days of occupancy of any room or rooms in a hotel or lodging house is subject to the room occupancy tax irrespective of the total period of occupancy. The charge attributable to occupancy after the first thirty consecutive days is not subject to the room occupancy tax.

LEGAL DIVISION

May 24, 1991