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 textbooks taxable when separately charged to students versus included in lump-sum tuition or registration for a course?
Separately stated textbooks and materials transferred to students were taxable. A lump-sum course charge including them was not taxable, but the course provider owed tax on the materials unless it qua…
When was parking-lot striping or restriping taxable repair rather than nontaxable scheduled maintenance, residential work, or new construction?
Regularly scheduled restriping performed before deterioration could qualify as nontaxable maintenance with records. Restriping after fading or cracking was taxable repair; new-construction and residen…
Were automobile window etching and the associated theft warranty taxable when the warranty was mandatory versus optional?
Window etching was taxable. If the etching could not be bought without the warranty, the full charge was taxable; if the warranty was optional, the warranty charge was not taxable.
Does New York tax a sale shipped from New York to an out-of-state customer, or a drop shipment, when the customer takes delivery outside New York?
No — New York does not tax these sales, because the customer takes delivery outside New York. Audio-Video Corporation, based in Albany, asked about two situations, both involving Florida sales reps wh…
Did selling petroleum products to a Connecticut municipality remove those receipts from the petroleum company gross earnings tax?
No under this historical ruling. The tax applied to the petroleum company's gross receipts and was not required to be passed through with the company acting only as collector, so the customer's status…
Did Company X have to collect sales tax on management services provided to partnerships owning Connecticut housing projects?
Yes under this historical ruling. The services were taxable, the low-income nonprofit housing exemption covered tangible property rather than services, and the partnerships had not shown qualifying no…
Could a nonprofit country club obtain a state refund of tax collected on nontaxable initiation and membership fees before returning or crediting the tax to members?
No. The club first had to refund each purchaser or, with the purchaser's permission, credit the purchaser's account and obtain written acknowledgment that the amount was a sales-tax refund. Only then …
When were residential land clearing and excavation services taxable under Connecticut Ruling 89-208?
Land clearing solely for new residential construction was not taxable. Excavation for new commercial or residential construction was also nontaxable, but excavation on existing industrial, commercial,…
When two owners exchanged Connecticut real-property interests by quitclaim deed, was each side subject to real estate conveyance tax?
Yes under this historical ruling. Each releasor made a taxable conveyance subject to state and municipal real estate conveyance taxes. Each tax base was the fair market value of the interest conveyed,…
Which energy, power, environmental, and industrial engineering design services were taxable under Connecticut Ruling 89-206?
Listed energy, power, environmental, water-resource, and pulp-and-paper engineering was not taxable, but building engineering, building planning or design, building programs, and interior design were …
Could a transfer of business assets through a financing lease qualify as an occasional sale?
Yes. Financing leases were treated as sales, so using a financing lease did not prevent a transaction that otherwise met the occasional-sale requirements from qualifying for exemption.
Were an entertainment agency's fees for booking independent bands at Connecticut locations subject to sales and use tax?
Yes under this revoked ruling. X Company operated as an employment agency and had to tax its band-booking fees whether charged to the client or band. Payments made directly to bands by third-party cli…
When were water-pump and water-purification installation or repair charges taxable under Connecticut Ruling 89-204?
Repairs were taxable on parts and labor. Installation in new construction or qualifying owner-occupied one- to three-family residential property, including full-system replacement, was not taxable. DR…
Were process-engineering services for industrial environmental problems subject to Connecticut sales and use tax?
No under this historical ruling. DRS said X Corporation's process-engineering services, including wastewater treatment and hazardous-waste management for industrial clients, were not taxable as buildi…
Did a residence with an attached business office qualify for Connecticut's residential electricity exemption?
Yes under this historical ruling if at least 51% of the entire building, including the residence and office, was occupied for residential dwelling purposes. DRS says Policy Statement 94(3) superseded …
When did electricity sold to a job shop qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate finished products for sale and at least 75% of all electricity consumed at the location, building, or premises was used for f…
When did electricity sold to an optical-lens fabricator qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate optical lenses for sale and at least 75% of all electricity consumed at the location, building, or premises was used for fabr…
When did electricity sold to an awning fabricator qualify for Connecticut's manufacturing utility exemption?
It was exempt under this historical ruling when used directly to fabricate awnings for sale and at least 75% of all electricity consumed at the location, building, or premises was used for fabrication…
Were optical analysis and design services for an orbiting X-ray telescope subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the professional optical-engineering services used to analyze and design an orbiting X-ray telescope for a company performing a government contract were not s…
How did Connecticut source building-engineering services performed or billed across state lines?
Connecticut work for Connecticut projects was taxable even when billed out of state. Work for projects outside Connecticut was not taxable when the service's sole benefit and use occurred outside the …
Was a municipal building-permit fee taxable when an architect obtained the permit for a client?
No under this historical ruling when the architect separately stated the permit fee on the client bill. DRS treated the architect as the client's agent in obtaining the municipal permit. DRS says AN 9…
How were house-cleaning referral commissions and full-service cleaning receipts taxed under Connecticut Ruling 89-195?
A referral service's contractor commissions were taxable employment-service fees, while residents' direct payments to contractors were not. A cleaning service billing residents owed tax on total recei…
Which road, parking-lot, demolition, HVAC, appliance, and residential installation services qualified as new construction under Connecticut Ruling 89-194?
The ruling exempted specified new-road, new-parking-lot, and qualifying residential installations, but taxed listed pipe, resurfacing, demolition, existing-building HVAC, driveway, sealing, and repair…
If a purchase order shows the sales tax separately, must the tax also be separately stated on later subcontractor progress billings?
No — showing the tax separately on the accepted purchase order is enough. New Ric Construction Company, Inc. separately stated the sales tax on its contract/purchase order, and its subcontractors late…
Are charges to a bank for repossessing vehicles a taxable service, and how are the repossessor's expenses and storage treated?
The charges to the bank are not taxable. Key Bank, N.A. hired vendors to recover and repossess vehicles from customers who defaulted on leases or loans, and asked whether those charges are subject to …
Are construction materials exempt when a tenant builds a new building on land owned by a tax-exempt religious corporation that takes title to the materials?
Yes — the materials are exempt from both state and city sales tax. 101 Limited Partnership leased land in New York City for 99 years from the Corporation of Trinity Church, a religious corporation tha…
Does an out-of-state company owe New York corporate franchise tax just because its employees taught four five-day training courses in New York, even though another state's tax rules would attribute the income to that other state instead?
Yes. Sending employees into New York to teach paid courses is sufficient presence to constitute "doing business" in New York and triggers Article 9-A franchise tax, regardless of whether another state…
How did Connecticut source sales and use tax on multistate tool-sharpening services?
The ruling sourced the service to the property owner's location. A Massachusetts tool owner did not owe tax for Connecticut sharpening, while Connecticut owners owed tax whether sharpening occurred in…
Were sales of copies of Hartford's official block maps and sewer profiles subject to Connecticut sales tax?
No under this historical ruling. DRS treated the official maps and sewer profiles as public records excluded from sales tax under Conn. Gen. Stat. § 12-15, even though the taxpayer charged a typical c…
Were engineering services for standby generator systems and related building modifications taxable under Connecticut Ruling 89-191?
Generator-system equipment design was not taxable, but engineering that designed the building or its modifications to house the equipment was taxable and had to be separately stated. DRS says AN 94(3)…
When did initial commercial finish-out count as nontaxable new construction rather than taxable renovation under Connecticut Ruling 89-190?
Initial finish-out of a new building, new addition, or first-sold office-condominium unit was nontaxable new construction. Work after initial finish-out—including changes for a new tenant in previousl…
How did Texas tax access fees, calls, private lines, equipment, and other telecommunications charges between Texas and Mexican facilities?
Texas taxed services originating in Texas and billed to a Texas billing or service address, including related access fees; Mexico-origin calls were not taxable, while Texas-origin calls were. Private …
Could affiliated businesses continue filing Texas sales-tax returns using thirteen 4-4-5 fiscal periods, and how were return months and due dates assigned?
Yes. Periods ending on days 1–10 were reported on the prior month's return due the 20th of that month; periods ending on day 11 or later were reported for that month and due the next month's 20th. Pre…
What export documents supported a Texas sales-tax refund, and how did the 30-day Texas storage presumption apply?
A broker export certificate or bill of lading proved export; an air waybill should include the seller's invoice number to identify the goods. The seller collected tax when the customer took Texas poss…
How were manufacturer and extended-warranty roof repairs taxed when commercial roofing warranties crossed Texas's January 1, 1988 real-property repair-law change?
Manufacturer-warranty repairs on sold roofing material supported resale treatment for third-party repair labor. Extended commercial-roof warranties required period-by-period treatment: pre-1988 repair…
Could a nonresidential sub-repairman issue a resale certificate using the general repairman's sales-tax permit number?
No. Each separate legal entity selling taxable items or services needed its own active permit and valid certificate. A sub-repairman's certificate using another entity's number was invalid; without it…
Were architects' feasibility studies evaluating whether office space met a client's needs subject to Connecticut sales and use tax?
Yes under this historical ruling. Studies evaluating whether office space had enough room for personnel, equipment, and expected growth were taxable building planning or design services. DRS says AN 9…
Were industrial wastewater-treatment and metal-finishing process-system design services subject to Connecticut sales and use tax?
No under this historical ruling. DRS said the two listed process-system design services and the source letter's unspecified non-design efforts were not taxable under the building-engineering provision…
When were forensic pipe inspections and industrial-equipment failure analysis taxable under Connecticut Ruling 89-187?
Pipe inspections in existing commercial, industrial, or income-producing buildings were taxable; inspections in new construction or qualifying owner-occupied one- to three-family homes were not. Indus…
Were geological site evaluations, feasibility studies, and water-and-soil assessments subject to Connecticut sales and use tax?
No under this historical ruling. DRS excluded Company X's geological services, including septic-site and groundwater studies, potential-water-source evaluations, and studies of streams, bedrock, lakes…
Was pond construction subject to Connecticut sales and use tax as a landscaping or horticultural service?
Yes under this historical ruling. Pond construction was taxable as landscaping and horticultural service work whether performed for residential or industrial, commercial, or income-producing property.…
Which surveying, structural, site, roadway, drainage, and septic engineering services were taxable under Connecticut Ruling 89-184?
Land surveying, survey work for subdivisions, structural building engineering, and road-construction stakeout were taxable. Site feasibility, site-development engineering, roadway and drainage design,…
Could a business-operations sale qualify as an occasional sale when the seller retained vehicles, trailers, and a lawn tractor?
Not if the entire business was being sold, because all operating assets had to transfer. A sale of an identifiable segment could qualify if the retained items served general business purposes rather t…
When could an equipment rental company accept a resale certificate for tents, arches, and food-service equipment rented by caterers, planners, or other rental businesses?
A true rental company could rent items tax-free for re-rental. Caterers were consumers and paid tax on equipment they used. For other customers, a properly completed certificate could be accepted when…
Were bags used by harvesters to pick citrus exempt from Texas sales and use tax as agricultural machinery or equipment?
Yes. Because the bags were used in the actual harvesting of food for human consumption produced for sale, they qualified as exempt agricultural machinery or equipment. STAR flags a later registration-…
How long was rent at the taxpayer's lodging house subject to Connecticut room-occupancy tax?
Rent for a room occupied for 30 consecutive calendar days or less was taxable. After the resident completed the thirtieth consecutive day, later rent was not taxable until continuity of the stay broke…
Was humane nuisance-wildlife removal from residential areas subject to Connecticut sales and use tax?
No under this historical ruling. The provider trapped raccoons, woodchucks, skunks, and similar animals, used no pesticides or poisons, did not kill them, and released them safely in state forests. DR…
When did Connecticut sales and use tax become due on an architect's retainer fee?
Tax became due when the architectural services were rendered or made available and the client became entitled to them, even if the architect received payment in an earlier or later filing period. DRS …
How were product-marketing strategy, packaging design, subcontracted design, and out-of-state design services taxed under Connecticut Ruling 89-180?
Product-marketing strategy and new-product design were exempt, while packaging and delivery-system design were taxable. Subcontracted design required tax unless resale applied; out-of-state use could …
When were takeout donuts and other food sales treated as taxable meals rather than bulk food under Connecticut Ruling 89-179?
Six takeout donuts generally were a bulk sale, but six donuts with six beverages were six taxable meals. Ready-for-immediate-consumption takeout food was taxable, while qualifying student-cafeteria me…
How were engine-repair labor and parts taxed for personal versus business vehicles under Connecticut Ruling 89-178?
Labor was exempt for a personal vehicle but taxable for a vehicle used in a trade or business; repair parts were taxable in both cases. Subcontracted parts and labor could be bought for resale with a …
Were power-line expansion design and small mobile control-building design subject to Connecticut sales and use tax?
No under this historical ruling. Professional engineering for expansion of power-line systems was exempt, and design of small mobile control buildings that were easily disassembled was not treated as …
Were optical-laboratory engineering services on test equipment for scientific-instrument mirrors subject to Connecticut sales and use tax?
No under this historical ruling. DRS said scientific engineering or physics-scientist services performed by a licensed professional engineer were generally exempt and applied that treatment to the des…
Were total receipts from an airport valet lot taxable when the price bundled parking, vehicle relocation, and shuttle transportation?
Yes under this historical ruling. DRS treated the valet service as including a parking space and taxed total receipts, including airport shuttle transportation, without allowing allocation of part of …
When did an out-of-state architect have Connecticut sales-tax nexus and registration duties under Ruling 89-174?
Entering Connecticut to view a project site or inspect construction created nexus even when architectural work occurred elsewhere. Post-July 1, 1989 services were taxable despite an earlier contract, …
Could a landscaper accept a resale certificate for work under a federal, state, or municipal government construction contract?
Yes under this historical ruling when the landscaping benefited real property owned by the exempt government entity. Landscaping and tree removal were otherwise taxable on total gross receipts. DRS sa…
Were licensed engineers' motor-vehicle accident-reconstruction receipts, including separately stated photos, subject to Connecticut sales tax?
No under this historical ruling. Total accident-reconstruction receipts, including separately stated photographs and prints, were not taxable. The engineer was the final consumer of film, photos, prin…
When did a grocery store's food sales count as taxable meals under Connecticut Ruling 89-171?
Food products were generally exempt, but ready-for-immediate-consumption meals sold by an eating establishment or caterer were taxable. Grocery stores were not eating establishments unless they provid…
Were traffic-impact studies and related roadway or signal design services subject to Connecticut sales and use tax?
No under this historical ruling. DRS excluded traffic-engineering services that evaluated proposed developments' roadway effects, recommended improvements for adverse traffic, and could include roadwa…
When did fuel used to heat an industrial manufacturing plant qualify for Connecticut's sales-tax exemption?
It was exempt under this historical ruling when at least 75% of the building, location, or premises was used directly in the manufacturing production process. DRS tied the heating-fuel exemption to Co…
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