State Tax Rulings
Free state tax letter rulings and advisory opinions with plain-English summaries, full citations, and the original source on every page.
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Were greens fees, golf lessons, and tennis lessons, clinics, or tournaments at public and private clubs taxable?
No under this historical ruling. Greens fees and golf lessons, plus tennis lessons, clinics, and tournaments, were not taxable at either public or private clubs. DRS marks the ruling not current and o…
Which vending-machine sales at Connecticut state community and technical colleges were exempt?
Cookies, cakes, pastries, chips, milk, and coffee sold from machines in student cafeterias, student-union areas, and dormitory hallways were exempt under this historical ruling. Candy and carbonated b…
Were Company X's MRI and lithotripsy agreements equipment leases, and could it acquire the equipment for resale?
No. Because Company X retained substantial control over access, maintenance, operation, personnel, and insurance, it provided a service rather than leasing equipment. It could serve qualifying nonprof…
Were Company X's tour receipts taxable, and how were its purchases used to provide the tours treated?
The tour receipts were not subject to sales and use tax under this historical ruling. Company X was the final consumer of purchases used to perform the tours and had to pay applicable sales tax and/or…
Did the Utah State Tax Commission rule on whether newspaper printing/finishing equipment qualifies for the manufacturing sales tax exemption?
No ruling was issued here. A newspaper publisher asked the Utah State Tax Commission to confirm that its facsimile-receiving, stacking, wrapping, and labeling equipment qualified for the manufacturing…
Are the fuels and electricity a clean-room manufacturer uses to build clean rooms exempt from Utah sales tax, and are 'clean rooms' themselves always exempt manufacturing equipment?
Yes for the manufacturer's own fuel and electricity: the Commission ruled the taxpayer, as a manufacturer of clean rooms, could buy fuel and electricity tax-free for use in manufacturing them. But 'cl…
Could a direct-payment permit holder obtain a later refund if it did not give the supplier a direct-payment exemption certificate when buying taxable items?
No. The permit holder could choose to pay tax at purchase, but if it did not issue the certificate then, it could not later claim a refund of tax that was properly due and paid. The later certificate …
Were city electrical-permit fees taxable when a contractor passed them through to residential or commercial customers?
No, if separately stated. This follow-up corrected the Comptroller's November 2 letter and said a city fee charged to the contractor remained nontaxable when passed to the customer, even on a taxable …
Could a planned two-building expansion of a South Carolina regional corporate headquarters qualify for a five-year property-tax exemption and an income-tax credit, including after a sale-leaseback?
Yes, conditionally. The two buildings could be treated as one headquarters expansion, the facilities could receive a five-year nonschool county property-tax exemption, and qualifying building and pers…
Could the Commissioner extend X Company's statutory deadline for reporting personal property located in Connecticut towns?
No. After reviewing the governing public act, the Commissioner concluded that he had no statutory authority to extend the legislatively established filing deadline and denied X Company's request for a…
Were model usage fees taxable, and could an advertising agency give the model agency a resale certificate?
The model usage fees were taxable as an employment service. The advertising agency using the models was the ultimate consumer, had to pay sales tax on the model agency's fee, and could not issue a res…
Were X's broad real-estate development consulting services taxable as architectural, building-engineering, or commercial-property services?
No under this historical ruling. The described feasibility, market, financing, site, permitting, planning, design-coordination, marketing, construction-management, and tenant work was not taxable arch…
Were lobbying services performed by an employee for the employee's association employer taxable?
No under this historical ruling. Although lobbyist services became taxable on July 1, 1989, services an employee rendered for the employer were outside the tax. DRS said the apparent association emplo…
Were consulting services provided to a Connecticut public school subject to sales and use tax?
No under this ruling. Connecticut DRS stated that consulting services provided to a public school were exempt from sales and use tax under Conn. Gen. Stat. § 12-412(1).
Were asbestos-removal services and the tangible property used to perform them subject to sales and use tax?
Under this historical ruling, asbestos-removal services were excluded as voluntary hazardous-waste containment or removal. Tangible personal property bought to perform those services remained taxable.…
Which engineering, survey, feasibility, design, and permitting services for marina development were taxable?
Under this historical ruling, bathymetric and hydrographic surveys were taxable land surveying, and building-engineering or building-design portions were taxable. Listed environmental, testing, market…
Which facilities counted as residential for the exemption from sales tax on gas, electricity, and heating fuel?
Under this historical ruling, apartment buildings, nursing homes, congregate housing, and halfway houses were residential and exempt for gas, electricity, and heating fuel. Hospitals, hotels, and mote…
Were asbestos site assessment, management analysis, removal planning, and abatement oversight taxable real-property services?
No under this historical ruling. The described asbestos assessment, removal-or-management analysis, plans, specifications, and abatement oversight were excluded as voluntary hazardous-waste containmen…
Was asbestos removal excluded from Connecticut sales and use tax as a hazardous-waste service?
Yes under this historical ruling. DRS treated asbestos removal as an excluded service for voluntarily containing or removing hazardous waste. DRS marks the information not current and says Special Not…
Did nursing homes and similar long-term health or chronic-care facilities qualify for Connecticut's residential utility exemption?
Yes under this historical ruling. DRS treated convalescent or nursing homes as residential, allowing them to claim the exemption through their utility and heating-oil suppliers and receive bill credit…
Was armored-car security for transporting precious-metal by-product bars to a refinery exempt as a service making a manufactured product more marketable?
No. The security service did not make the bars more marketable, so the manufacturing-service exemption in § 151.318(a)(3) did not apply and the provider could not accept an exemption certificate.
Which fabrication, installation, component-part, fixture, and repair charges were taxable under Connecticut Ruling 89-237?
Fabricated brackets, supplemental production-machinery parts, fixtures, and tangible-personal-property repairs were taxable on their full receipts, including labor and materials. Bracket installation …
Were aircraft charter receipts, aircraft-sale brokerage fees, and aircraft-storage rentals subject to Connecticut sales and use tax?
Charter receipts were taxable when a certificated carrier used in Connecticut an aircraft bought and held for resale, and brokerage fees were taxable for Connecticut aircraft sales. Aircraft-storage r…
Did Connecticut's residential utility exemption cover electricity and heating fuel used in condominium common areas and recreation facilities?
Yes under this historical ruling, if the entire condominium complex was predominantly residential. The exemption covered association-billed common areas and a condominium social club's on-site recreat…
Were services that reviewed and minimized clients' property tax assessments subject to Connecticut sales and use tax?
No under this historical ruling. DRS said X Company's service of reviewing and minimizing property tax assessments imposed on its clients was not subject to sales and use tax.
Were qualifying animal feed sales exempt, and were farmers exempt from repair-labor charges, under Connecticut Ruling 89-233?
Qualifying feed for livestock, rabbits, and poultry ordinarily used as human food was exempt without an exemption certificate. Farmers were not exempt from labor charges for repairing tangible persona…
Were total receipts from landscape, horticultural, and tree-removal services subject to Connecticut sales and use tax?
Yes under this historical ruling. Total gross receipts from landscape and horticultural services were taxable, and tree removal counted as a horticultural service. DRS marks the information not curren…
Was labor to add a second floor inside an existing warehouse nontaxable new construction even though the roof was not raised?
Yes for the second-floor portion. The November letter reversed the attached October answer and treated the added floor as new construction with nontaxable labor; separate remodeling or warehouse-to-ma…
Did a merger and deed transfer between two commonly owned corporations trigger Connecticut's controlling interest transfer tax?
No under this revoked ruling. DRS treated the transaction as a real-estate conveyance rather than a controlling-interest transfer and found the deed exempt under Conn. Gen. Stat. § 12-498(a)(7). DRS s…
Which asbestos-removal, relocation, restoration, and renovation services were excluded from Connecticut sales tax?
Actual asbestos removal, containment, and disposal were excluded, as were directly related relocation and comparable-material restoration services. Renovations that enhanced or improved the area were …
Was the 40% commission retained by a nonprofit arts school's store for selling artists' consigned goods subject to Connecticut sales tax?
Yes under this historical ruling. The nonprofit school acted as a sales agent and its retained 40% of the selling price was a taxable fee or commission. DRS marks the information not current and says …
Did X Foundation owe Connecticut sales tax on utility services purchased for its headquarters, including utilities associated with leased space?
No under this historical ruling. DRS said no sales tax was due on utility services purchased by X Foundation, whose property, income, obligations, and activities were exempt under Conn. Gen. Stat. § 1…
Could a farmer obtain Connecticut's agricultural sales-tax exemption permit without at least $2,500 of agricultural-product sales in the preceding year?
No under this historical ruling. DRS could issue the permit only when the farmer reported at least $2,500 of agricultural-product sales for the preceding calendar year. The law provided no startup exc…
Were barter-club membership fees, sales-agent services, and bartered transactions subject to Connecticut sales tax?
Membership trade-account fees were not subject to sales tax or admissions, dues, and cabaret tax. Sales-agent services were taxable, and Connecticut businesses had to charge sales tax on barter transa…
Did a photocopying machine qualify for Connecticut's machinery sales-tax exemption under Conn. Gen. Stat. § 12-412(18)?
No under this historical ruling. DRS said a photocopying machine was not exempt because copying printed pages was not considered manufacturing or fabricating an item of tangible personal property.
Were environmental engineering services taxable, and how did Connecticut treat building design included with those services?
Environmental engineering services were not taxable under this historical ruling, but designing a building to house a facility such as a water-treatment plant was taxable and had to be separately stat…
Are a tenant's contractors exempt from sales tax on materials built into a building whose title vests in the tax-exempt Port Authority?
Yes — the materials are exempt. Salomon, Inc. leased office space in 7 World Trade Center and planned major structural improvements. The land under the building is leased from the Port Authority of Ne…
Are electronic voice-messaging and telephone-answering services a taxable telephone/telegraph service, and how are they sourced and rated?
Yes, they are taxable telephone/telegraph services. G.T.E. Telemessager Incorporated runs a computerized voice-messaging network ('VMX') that lets subscribers store, retrieve, redirect, and broadcast …
Does hiring a New York lettershop to mail catalogs make an out-of-state mail-order company a New York vendor that must register and collect sales tax?
Hiring the New York lettershop does not, by itself, make the out-of-state company a New York vendor — but its own solicitation of New Yorkers can. Geran Mailing, Inc., a New York direct-mail (lettersh…
Were land-use planning, development-team coordination, and regulatory-process administration services subject to Connecticut sales and use tax?
No under this historical ruling. DRS did not classify X Company's services as taxable architectural or building-design, business-consulting or public-relations, or governmental lobbying or consulting …
How did a seasonal cotton gin establish predominant use and obtain an electricity exemption or refund for qualifying processing periods?
Predominant use was measured during the months the gin actually processed cotton, so only qualifying billing periods were exempt. If the utility could not split exempt and taxable periods, the gin pai…
How were residential light fixtures and yard lights taxed when sold and installed under a separated contract?
The installed lights were improvements to realty. The seller collected tax on the separately stated fixture price, while labor to install the fixtures on residential property was not taxable.
Is encoding a TV commercial a taxable service the monitoring company must pay, and are the broadcast-monitoring reports it sells taxable?
The two charges are treated differently. VidCode Inc. verifies for advertisers whether their TV commercials actually aired as contracted, by first encoding a unique signature onto the master copy of e…
How were manufacturer warranties, extended warranties, repair parts and services, and mixed maintenance contracts taxed under Connecticut Ruling 89-152?
Manufacturer-warranty repairs and parts were nontaxable. Extended-warranty repairs and parts were taxable, though the contract sale itself was not; no-charge parts triggered use tax, no-charge service…
How were stand-alone backflow testing, testing with repairs, installation, design, drafting, and inspection taxed across new, residential, and existing commercial property?
Stand-alone testing and inspection were generally nontaxable; separately stated testing stayed excluded from taxable existing-commercial repairs. New-construction and residential jobs followed contrac…
Were animal boarding and grooming services taxable for pets, food-producing animals, horses, mules, or work animals?
Animal boarding was not taxable. Cosmetic pet grooming was taxable, but grooming animals whose products ordinarily become human food, as well as horses, mules, and work animals, was not taxable.
Was photoengraving a manufacturing production process that qualified its machinery for Connecticut's sales-tax exemption?
No under this historical ruling. DRS classified photoengraving as processing, not manufacturing, because it did not substantially change personal property's form, composition, or character. The machin…
Was a chair that elevated a disabled person from a sitting position exempt from Connecticut sales tax?
No under this historical ruling. DRS said the chair's sale was subject to Connecticut sales tax because no specific exemption applied to it.
Were fire-scene analysis services performed for insurance companies subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the described fire-scene analyst services—determining cause, insured involvement, documenting for possible subrogation, and reporting findings—were not taxabl…
Was insurance appraisal work subject to Connecticut sales and use tax under Ruling 89-219?
No under this historical ruling. DRS said insurance appraisal work was not subject to sales and use tax, but it marks the information not current and says Ruling 94-10 superseded the ruling.
Were X-ray or chemical inspection services taxable when performed on real property or tangible personal property?
Inspections of industrial, commercial, or income-producing real property were taxable except for new construction, while inspections of tangible personal property were not taxable. DRS marks the guida…
Could capital losses reduce income other than net capital gains for Connecticut corporation business tax purposes?
No under this historical ruling. DRS said capital losses under Conn. Gen. Stat. § 12-217(a) could be used only to offset net capital gains. In the cited examples, combined taxable income was $200, inc…
Did component parts bought separately for numerically controlled machinery qualify for Connecticut's machinery sales-tax exemption?
No under this historical ruling. Component parts purchased separately from the original machine did not qualify under Conn. Gen. Stat. § 12-412(34); only components bought with the original machine we…
What ownership level was required for Connecticut's sales-tax exemption for services between affiliated corporations?
The corporations had to be connected through 100% parent-subsidiary ownership and control or 100% brother-sister ownership and control. The historical ruling rejected the 80% federal controlled-group …
Which water- and sewer-plant engineering and building-design services were taxable under Connecticut Ruling 89-214?
General engineering was not taxable, but design work for a permanent building housing process facilities was taxable. Subcontracted building design could be bought for resale, while easily disassemble…
Was creating trade-show exhibits a manufacturing production process for Connecticut sales and use tax purposes?
No under this historical ruling. DRS said creating trade-show exhibits was not a manufacturing production process and instead was governed by the contractor regulations in Conn. Agencies Regs. § 12-42…
Which landscape-planning services were nontaxable, and was landscape architecture taxable, under Connecticut Ruling 89-212?
Site assessment, environmental-impact studies, schematic concepts, site planning, plan review, rezoning requests, and wetlands approval were not taxable. Landscape architecture was taxable as landscap…
Did prepress computers and peripheral equipment qualify for Connecticut's manufacturing machinery exemption?
No under this historical ruling. DRS said prepress production machinery was not used directly in manufacturing a finished product for sale and therefore did not qualify under Conn. Gen. Stat. § 12-412…
Was a charge to interface application software products purchased from a third party subject to Texas sales tax?
No. The Comptroller said the described third-party software interface work was not a taxable service under the tax law then in effect.
Were charges for computer-calculating survey data and filing completion reports taxable when part of professional engineering services?
No. The computer was merely a tool used to perform nontaxable professional engineering rather than a separately sold data-processing service, and the related state-office completion-report filing char…
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