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 the Shuttle tri-wheel scooter or wheelchair and the Liftami electric vehicle lift exempt from Texas sales tax?
The Shuttle was exempt as an orthopedic appliance without a prescription. The Liftami qualified as an exempt therapeutic device only when sold, leased, or rented to an individual under a licensed prac…
Were pest-control services exempt merely because they were performed at a school district property through another maintenance company?
No. The pest-control provider charged tax unless the maintenance company gave a resale certificate for resale to the district or had a legal agency agreement allowing an exemption certificate. Reimbur…
Were lease payments taxable in a sale-leaseback of equipment the customer had used for years and already paid Texas tax on?
No. On the stated facts, the Comptroller treated the sale and leaseback as financing: the customer had used the equipment for three to five years and already paid tax, kept possession and operating bu…
How were utility-tax refunds, miscellaneous utility charges, service plans, fees, and exemption certificates handled under Connecticut Ruling 89-168?
Utilities credited refunds and offset current or later remittances. Utility service charges and service plans were taxable; installation, utility-owned equipment work, late fees, and bad-check fees we…
Which surveys, stakeout work, site plans, road and sewer designs, septic designs, and feasibility studies were taxable under Connecticut Ruling 89-167?
Boundary, topographic, plot-plan, mapping, and all listed stakeout services were taxable surveying. Road, sewer, utility, pond, site-plan, septic, hydraulic, hydrologic, and feasibility engineering we…
Were a detailer's simplified roofing and siding drawings subject to Connecticut sales and use tax as architectural or engineering services?
No under this historical ruling. The detailer extracted and condensed approved architectural and engineering information for bidding, materials, fabrication, erection, and field use, but DRS did not c…
Were systems-engineering services for glass machinery used to fabricate telescope optics subject to Connecticut sales and use tax?
No under this historical ruling. DRS said systems engineering for glass machinery used to fabricate telescope optics was not taxable under the building-engineering and design provision. DRS marks the …
Were road-and-bridge design and inspection services for a nongovernmental entity subject to Connecticut sales and use tax?
No under this historical ruling. DRS said civil-engineering services such as road and bridge design, together with inspection of those projects for a nongovernmental entity, were not subject to sales …
Could an equipment manufacturer buy contractor-developed software discs for resale without Connecticut sales and use tax?
Yes under this historical ruling only if the discs were resold unchanged and the manufacturer retained no proprietary right. Software-disc sales were otherwise taxable, even though the equipment could…
Were motor-vehicle accident-reconstruction advice and expert court testimony subject to Connecticut sales and use tax?
No under this historical ruling. DRS said accident reconstruction, expert advice to attorneys and insurers in motor-vehicle liability cases, and court testimony about accident causes were not subject …
How were environmental assessments, remediation planning, underground-tank removal, ancillary design, and surveying inputs taxed under Connecticut Ruling 89-161?
Assessments, air/soil/water testing, ancillary sewer and septic design, licensed remediation planning, and underground-tank removal were not taxable. The engineer was final consumer of materials and t…
Which hydrology, highway, environmental, soil, site, approval, project-management, inspection, and surveying services were taxable under Connecticut Ruling 89-160?
The listed engineering, approval, estimating, management, supervision, and inspection services were not taxable. Boundary and topographic surveys and construction staking were taxable land surveying. …
Could a contractor acting as agent for a direct-payment-permit holder buy construction consumables tax-free with the customer's permit?
No. A private agency agreement could not shift the tax incidence. Rule 3.291 required the contractor to pay tax on consumables, and Rule 3.288 limited the permit to items the holder bought for its own…
Were emergency medical ambulance standby services at municipal, church, civic, or special private events subject to Connecticut sales tax?
No under this historical ruling. DRS said emergency medical ambulance services hired to stand by at municipal, church, civic, or special private events were not subject to sales tax.
Were sales, leases, or rentals transferring dominion and control of computer software subject to Connecticut sales and use tax?
Yes under this historical ruling. DRS treated software as tangible personal property, included leasing within sales, and said transferring dominion and control was a taxable lease or rental rather tha…
Did Connecticut's tobacco products tax apply to every cigar, including one not yet prepared or aged enough to be suitable for smoking?
No under this historical ruling. The tax applied to cigars prepared so they were suitable for smoking, not cigars that were not yet suitable. Whether aging made a cigar suitable was factual and requir…
Were X Company's purchases exempt when an exempt resource-recovery facility reimbursed the company for the tax as an operating expense?
No under this historical ruling. X Company was not exempt, reimbursement did not convert its purchases into exempt purchases, and only direct purchases by the Bristol Resource Recovery Facility were e…
What operating, licensing, withholding, account, staffing, card, and gross-proceeds rules did South Carolina Revenue Ruling 89-23 apply under the Bingo Act of 1989?
The ruling limited a session to noon through midnight, required both licenses to be displayed, required 7% withholding on prizes of $500 or more, and allowed assessments against the promoter, nonprofi…
Were sewer services exempt from Connecticut's sales tax on utility service?
No under this historical ruling. DRS said sewer services were not exempt from the sales tax imposed on utility service.
Did a Fort Worth seller have to collect Abilene's new 1990 city and industrial-development sales taxes, and how did prior-contract relief vary for new local districts?
No. The Abilene taxes were treated as city sales taxes, so a Fort Worth place of business did not collect them. Three-year prior-contract relief applied to the Abilene taxes and some crime-control or …
Could a parent company file one consolidated Texas sales-tax return for 48 wholly owned subsidiaries operating stores in Texas?
No. Each subsidiary was a separate legal entity and had to file its own return. One consolidated return would have been possible only if the stores were divisions of one legal entity rather than separ…
Did American Red Cross chapters making taxable sales have to obtain Texas sales-tax permits, pay the permit fee, and collect tax despite governmental-entity status?
Yes. The Red Cross remained a governmental entity, but an attorney general opinion required any governmental entity making taxable sales to be permitted, pay the fee, and collect and remit tax like ot…
Did Texas's historical modified-vehicle exemption apply when the vehicle was bought before the person's disability?
No. The Deputy Comptroller said motor vehicle sales tax was fixed at purchase, so a later disability and vehicle modification did not make the original sale exempt. The agency did not reclaim the alre…
How did Connecticut tax accident-reconstruction engineering inputs, government reimbursable expenses, and multistate shopping-center management?
Licensed accident reconstruction was exempt, but the engineer owed tax on inputs and could not buy them for resale. Government-agency reimbursable expenses and management of a Connecticut shopping cen…
Did a precision sheet-metal manufacturer qualify for Connecticut's sales-tax exemption on electric bills?
Yes under this historical ruling. X Company manufactured precision sheet-metal components for aircraft, medical, and commercial uses to customer designs and specifications, and DRS said it qualified f…
Did a nonprofit historical organization collect tax on books and newsletters it published and distributed, and did it pay tax on its own organizational purchases?
No. The organization did not collect sales tax on its qualifying books and newsletters and was also exempt from paying sales tax on taxable items purchased for its own use.
Were carwash sand-trap and restaurant grease-trap pumping charges taxable, and could scheduled preventive service qualify as maintenance?
As-needed pumping and related plumbing cleaning on nonresidential property were taxable repairs. Documented, scheduled, periodic preventive pumping could be nontaxable maintenance, whether the trap co…
Could a seller exempt Fastrack sold as feed for farm and ranch animals when the product also had nonexempt uses?
Yes, with a purchaser exemption certificate stating the product was bought for farm or ranch animal feed. One blanket certificate per customer covered later qualifying purchases. STAR flags a registra…
Was the standalone creation of a freelance article taxable as consulting, public relations, advertising, or tangible personal property?
No under this historical ruling. Article creation without placement or dissemination involvement was not consulting or public relations, and the article was not taxable tangible personal property. The…
Were computer-assisted leak-detection testing services for underground petroleum and chemical storage tanks taxable?
No. The testing charge was nontaxable even though the provider used a computer in its vehicle. As a nontaxable service provider, it paid tax on the computer and other taxable items used to perform the…
Are consumer-marketing analysis reports built from a large shared database a taxable information service, or an exempt personal/individual service?
They are taxable. National Demographics and Lifestyles, Inc. sold manufacturers marketing reports — a Consumer Analysis Report, an NDL F/O/C/U/S report, and a Market Development Index — plus annual su…
What documentation, billing, payment, and exemption-certificate conditions applied to Connecticut sales-tax exemption for federal credit unions?
The credit union had to establish federal status with organization documents, be billed directly, pay directly, and give each retailer a completed certificate for each sale. Employee-billed purchases …
Did Al-Anon have to collect and remit Texas sales tax on literature that it published and distributed?
No. The Comptroller confirmed that, as of August 28, 1989, Al-Anon did not have to collect or remit sales tax on literature it both published and distributed. The letter said a revision to Rule 3.299 …
Does producing office furniture — cutting and welding steel parts, powder-coat painting, and upholstering chairs and panels — count as "manufacturing" for New York's investment tax credit and economic development zone tax credit?
Yes. Gathering raw materials and cutting, welding, painting, and upholstering them into finished office chairs and modular panels is "manufacturing" under the statutory definition, qualifying the acti…
How did Texas tax industrial gases, propane, sterilizing or cleaning gases, breathing-air refills, and cylinders when the buyer supplied only limited use facts?
The result depended on use. Gases consumed in manufacturing or protecting the product or environment could be exempt, while repair, sterilizing-water, and tank-cleaning uses were taxable. Propane was …
When were wigs, toupees, hair pieces, replacement parts, and repair or maintenance services exempt from Texas sales tax as prosthetic devices?
They could be exempt when bought to replace hair missing from the body. Specifically designed replacement parts and repair or maintenance of a qualifying prosthetic hair piece were also exempt. Cleane…
New York Advisory Opinion TSB-A-89 (9)I: Issue raised is whether the maximum tax provisions contained in section 603-A of the Tax Law, as in effect prior to repeal, apply to a limited partner's distributive share of partnership income for 1985 and 1986, where the partnership's income is derived from services performed on its behalf by its partners, where the limited partner had relatively little capital invested in the partnership, and where he was allocated his distributive share as compensation for personal services actually rendered by him to and on behalf of the partnership.
It depends on facts to be resolved in audit. If Mr. X's distributive share is found to derive from personal services he actually performed, to be 'earned income' of the partnership, and capital is not…
Was federal retail sales excise tax included in the Texas motor vehicle sales tax base?
No. The 1989 letter said the federal retail sales excise tax was imposed on the retail purchaser rather than the manufacturer, so it was excluded from total consideration subject to Texas motor vehicl…
How did Texas tax gifts shipped directly outside the state, prizes stored in Texas before out-of-state use, and mailer services?
Texas tax was not due when Texas suppliers shipped gifts directly to the company's out-of-state offices. Texas-purchased prizes stored in Texas before outside use were taxable, while items bought outs…
Did the Dallas/Fort Worth International Trade Resource Center qualify for Texas sales-tax exemption as a chamber of commerce?
Yes. The Comptroller classified the Resource Center as a chamber of commerce because it promoted the advantages of doing business in the Dallas-Fort Worth area, assuming it remained a nonprofit organi…
Could close corporations and federal S corporations use their federal-income-tax accounting method to compute Texas franchise tax under the new 1989 law?
Yes, optionally, for reports originally due after December 31, 1989. A close corporation or federal S corporation had to be eligible by the original due date for an initial report or by May 1 for an a…
Could preprinted farm-use language on a sales invoice replace a Texas exemption certificate, and what information did an invoice-based certificate need?
No. The proposed preprinted statement was insufficient. An invoice could serve as the certificate only if it contained the purchaser and seller names and addresses, item description, a purchaser-compl…
Was a service that arranged trademark licensing agreements subject to Connecticut sales and use tax?
No. Based on the stated facts, the service provider arranged agreements between the trademark-owning corporation and manufacturers for use of the trademark, and DRS concluded that the arrangement serv…
Which building, roadway, roof, floor, addition, and demolition work counted as renovation or new construction under Connecticut Ruling 89-148?
The ruling classified a below-foundation floor expansion, a new building addition, and specified added space as new construction; parking-lot lowering, existing-road reconfiguration, and specified roo…
Did the described meat manufacturer qualify for Connecticut's sales-tax exemption on utility bills?
Yes under this historical ruling. The business cut or reshaped raw product, heat-treated it, changed product characteristics with seasonings, and formulated sausages. DRS concluded that it qualified f…
Were charges for storing fur coats or cloth coats subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-144 concluded that charges for storing fur coats or cloth coats were not subject to sales and use tax.
How did a married couple filing separate federal returns have to file Connecticut's capital gains, dividends, and interest tax return?
They had to file separate Connecticut Capital Gains, Dividends and Interest Income Tax returns. DRS marks the information not current and says Announcement 94(2) obsoleted the ruling.
When were labor charges for installing, repairing, or replacing water systems taxable under Connecticut Ruling 89-142?
Installation labor was nontaxable for new construction and qualifying owner-occupied one-to-three-family residential property, but taxable for existing commercial or income-producing property. Repair …
Which boat-related training, storage, charter, washing, lifting, and surveying charges were taxable under Connecticut Ruling 89-141?
Classroom education, winter storage, mast removal, charter-location fees, lifting, and surveying were nontaxable; training sold with a boat and boat washing were taxable. DRS says 1996 Public Act 232,…
Were jewelry appraisals, jewelry or clock repairs, and engraving services taxable under Connecticut Ruling 89-140?
Jewelry appraisals were nontaxable. Jewelry and clock repair labor and parts were taxable. Engraving was taxable when part of a property sale but nontaxable when performed on customer-owned property. …
Is cellular telephone service taxable, are all its bundled charges taxed, and what local rate applies?
Yes — cellular service is taxable, and all its bundled charges are taxed. Cellular Telephone Company (trading as Metro One) asked whether its two-way mobile telecommunications service is subject to ta…
Were forensic engineering services subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-139 concluded that forensic engineering services were not subject to sales and use tax.
Was a book exempt when published by a nonprofit historical organization but marketed and distributed through a separate commercial press?
No. The exemption required the qualifying nonprofit to publish and distribute—ship, market, or sell—the writing. Because the commercial press appeared to handle distribution, the book sale was taxable…
Did resale certificates issued to the previous owner of an acquired business remain valid for the new owner?
Generally yes: the purchaser, not the seller, invalidated or revoked a valid resale certificate, so a prior owner's valid certificate carried over to the new owner of an existing business. But the sam…
Were all receipts from Company X's valet parking service subject to Connecticut sales tax?
Yes. The total receipts were taxable because valet parking included all aspects of the parking service, including providing spaces, and the company could not break out a separate valet component. DRS …
How did Connecticut tax adjustment and testing of air-conditioning, heating, ventilation, and exhaust systems?
Adjustment receipts were taxable for residential or commercial real estate. Testing was nontaxable in new construction and existing one-, two-, or three-family exclusively residential owner-occupied p…
Did apple refrigeration equipment and a replacement compressor qualify for Connecticut's agricultural-production exemption?
Yes under this historical ruling. Refrigerating apples to prevent deterioration was direct use in agricultural production, so the replacement compressor qualified for a sales-and-use-tax refund. The r…
Were voice-over services provided to public relations agencies subject to Connecticut sales and use tax?
No. Connecticut Ruling 89-135 concluded that providing voice-over services to public relations agencies was not subject to sales and use tax.
How did Texas tax new underground-cable construction, moving existing buried cable for road work, and repairing or replacing that cable?
New construction followed the contractor rules: a lump-sum contractor paid tax on materials and did not collect from the customer, while a separated contractor could buy incorporated materials for res…
Did a nonprofit genealogical society collect Texas sales tax on books it published and sold, and on books written by individuals?
Its own books were exempt because qualifying nonprofit organizations' writings were not taxable when the organization both published and distributed them. Books published by individuals but merely sol…
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