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 parts and labor to repair manufacturing production machinery taxable under Connecticut Ruling 89-51?
Yes. Repair or replacement parts and repair labor for production machinery were subject to 5.5% sales or use tax. The statute's $7,500 manufacturer refund applied to qualifying parts, not labor charge…
Were safety shoes selling for less than $75 taxable under Connecticut Ruling 89-50?
No, if the safety shoes were suitable for everyday use and their total sales price was less than $75. The ruling is superseded and the historical price threshold should not be assumed current.
Could a non-broadcaster providing television studios and post-production facilities claim Connecticut's broadcast-production equipment exemption?
No. The exemption applied only to television or radio stations, so the facility provider had to pay sales or use tax on its materials and equipment. Its charges to clients for using the facilities and…
Were monthly motor-vehicle lease payments taxable for lease periods beginning on or after July 1, 1989 under Connecticut Ruling 89-48?
Yes. Monthly motor-vehicle lease payments were subject to sales tax for lease periods on or after July 1, 1989. The referenced 90-day transition rule applied only to tangible-property sales contracted…
When were road or parking-lot grading services taxable under Connecticut Ruling 89-47?
On industrial, commercial, or income-producing property, grading for new roads or parking lots was not taxable, but grading to repair or rebuild existing ones was taxable. Residential grading was not …
Would Connecticut follow a corporation's federal I.R.C. § 338(h)(10) election when computing corporation business tax?
Yes. The Department concluded that Connecticut corporation business tax liability would follow federal law and incorporate the effects of the corporation's I.R.C. § 338(h)(10) election.
Were a new truck chassis and the separately stated charge to install it taxable under Connecticut Ruling 89-45?
The chassis sale was taxable, but a separately stated charge to install the new chassis on a motor vehicle for a truck dealer or end user was not. A truck dealer could buy the chassis for resale witho…
Did a partnership's capital gain recognized on January 10, 1989 qualify for Connecticut's 60% capital-gains exclusion?
Yes. The ruling said the gain qualified because capital gains earned, actually or constructively received, accrued, or credited on or before February 8, 1989 were eligible for the 60% exclusion. The r…
Were sales of gas or electricity to nursing or convalescent homes taxable under Connecticut Ruling 89-43?
No. The ruling exempted gas or electricity sold to nursing or convalescent homes for their use from sales or use tax. The ruling is superseded.
How did Connecticut Ruling 89-42 tax systems-design training provided to individuals and businesses?
Training provided to individuals was not taxable if it was not connected with a sale of tangible personal property. The same systems-design training provided to businesses was subject to sales or use …
How did Connecticut Ruling 89-41 determine the conveyance-tax rate for mixed-use property, and were realtor or appraisal services taxable consulting?
The conveyance-tax rate for mixed residential and commercial property followed the property's predominant use. The cited taxable-service provision did not tax realtor services for selling, leasing, or…
Did the company's custom certificate form satisfy Texas resale and exemption certificate requirements?
No. The Comptroller said the submitted form omitted required information and directed the company to Rule 3.285(a) and (d)(2) for resale certificates and Rule 3.287(a) and (f) for exemption certificat…
Were Texas calligraphy charges taxable, and how were resale work, materials, and donations treated?
Paid calligraphy and camera-ready artwork were taxable, including work on customer-supplied items. A resale certificate shifted collection to the reseller. Donated labor had no taxable consideration, …
Was electricity for bottling conveyors and plating hoists exempt as manufacturing use?
Only a conveyor built into and powered by the same motor as bottling machinery was treated as manufacturing equipment. Separately powered conveyors and plating hoists were intraplant transportation eq…
When a property owner pays a management company for workers, are the payments exempt wages, and is the management fee taxable?
The payments are not exempt wages, and whether the whole charge is taxable depends on what the worker does. A CPA firm asked about property owners that hire a management company to recruit and pay wor…
Could disposable tray liners provided to food-service customers be bought tax-free for resale?
Yes. Disposable, nonreusable tray liners provided to customers could be purchased with a resale certificate whether they were plain white paper or printed with advertisements.
Are purchases, leases, and service contracts for equipment at a project owned by an Industrial Development Agency and used by a private company exempt from sales and use tax?
They are exempt, so long as the Industrial Development Agency owns the property. The Chase Manhattan Bank, N.A. planned to relocate a financial-services processing center to Brooklyn under a New York …
Under South Carolina's permanent 1989 guidance, what did a payor have to withhold from proceeds paid to a nonresident seller of real estate and associated tangible personal property?
The payor generally had to withhold 7% of net proceeds paid to a nonresident seller, or 5% when the seller was a corporation or an association or trust taxed as one. The rule covered real-estate inter…
Did a Texas parachute broker collect tax on parachute sales and periodic airing, inspection, and repacking?
The broker did not collect use tax on out-of-state manufacturers' parachute sales, although Texas purchasers still owed the tax. The broker did collect sales tax on its full parachute-packing charge b…
Were labor, materials, and replacement parts used to repair railroad rolling stock taxable in Texas?
No. Because locomotives and rolling stock were themselves exempt, labor and materials for their repair or maintenance were exempt. The repairer could accept an exemption certificate and buy incorporat…
Could restaurants and caterers buy disposable cheesecloth lemon wraps without Texas sales tax?
Yes, with a valid resale or exemption certificate. Without one, the manufacturer properly collected tax. Buyers that had paid tax in error could later provide a certificate and seek a refund, subject …
Were gangway rentals to foreign-flag and domestic vessels taxable in Texas?
Yes. Gangways were tangible personal property, so their rental was taxable for both foreign and domestic vessels. A port authority's requirement to use a proper gangway did not create an exemption.
What happened when a seller mixed taxable crushed gravel with nontaxable unprocessed gravel?
The entire mixture was taxable. The seller could preserve the nontaxable treatment of unprocessed gravel only by keeping it separate and charging tax solely on sales of processed material.
Was processing insurer-supplied data against a database and returning driver-location reports taxable?
Yes. Processing customer-provided information was taxable data processing, while gathering or compiling information for customers was a taxable information service. The described business appeared to …
Which dry-cleaning and garment services were taxable under Connecticut Ruling 89-40?
Mending and deterioration-prevention work was taxable repair or maintenance, while separately stated alterations were not. Monogramming and embroidery were generally taxable, but fur storage, coin-ope…
Could later accumulated or credited dealer discounts reduce the taxable price of catalogs and advertising materials under Connecticut Ruling 89-39?
No. Both proposed discount methods left the normal selling price taxable because the discounts were not allowed and taken at the time of sale. Only a discount allowed by the company and taken by the d…
Was equipment installed by a private aviation company in a city-owned leased building exempt from Texas sales tax?
No. The equipment purchase and installation were taxable; if the equipment became part of the existing nonresidential building, the full charge was taxable remodeling.
When were third-party freight charges excluded from Texas sales tax?
Only when the independent carrier merely transported the goods and the retailer did not bill, account for, or prepay the freight. Retailer-accounted freight was taxable.
Can a Texas-exempt organization buy electricity tax-free and recover tax paid to its utility?
Yes, when the electricity serves the organization's exempt purpose. It must give the utility an exemption certificate and seek any refund from the utility, limited to the prior four years.
How did Connecticut Ruling 89-38 treat renovation services, tax-included billing, subcontractors, and installment payments?
New construction included services through first-tenant occupancy. A bill could say 'Tax Included' if records supported its components; the service portion equaled the total including profit minus mat…
Were aircraft brokerage services taxable when the aircraft sale and transfer of title occurred in Connecticut under Ruling 89-37?
Yes. The ruling applied sales tax to brokerage services when the aircraft sale, defined as the transfer of title, took place in Connecticut. The ruling is obsolete.
Which entertainment counted for Connecticut cabaret tax under Ruling 89-36?
Comedians, magicians, hypnotists, and disc jockeys counted as 'other entertainment.' A place serving or selling alcohol generally triggered cabaret tax when it charged for admission or refreshments an…
Were personal-residence inspection services taxable under Connecticut Ruling 89-35?
No. The ruling said personal-residence inspections were not subject to sales and use taxes. The official page says the ruling was later obsoleted in part.
How did Connecticut Ruling 89-34 tax driveway sealing and caretaker labor?
Driveway sealing was subject to sales tax, while labor for services performed as a caretaker was not. The official page says the ruling was later obsoleted in part.
Was gain from employees' forced stock sales in corporate takeovers subject to Connecticut's former capital-gains tax?
Yes. Because the forced-sale gains were taxable for federal income-tax purposes, the ruling also treated them as Connecticut capital gains under the former dividends, interest income, and capital gain…
Was X Company's humane animal-relocation service taxable under Connecticut Ruling 89-32?
No. Based on the facts in the request letter, the ruling said X Company's humane animal-relocation service was not subject to sales tax. The official page says the ruling was later obsoleted in part.
Could the redacted party give a resale certificate for remodeling work that added newsstand facilities at an airport?
Yes, under the stated arrangement. Title passed at completion, while the redacted entity received operating rights and a later fair-market-value payment.
What Texas tax duties applied to an out-of-state fundraising seller with a salesperson soliciting orders in Texas?
It had to obtain a Texas permit and collect applicable state and local use tax on taxable sales, even if many customers bought for resale or qualified for exemptions.
When could an exempt club buy restaurant meals tax-free for its meetings and programs?
When the club was the customer on the invoice, the meal served its exempt purpose, and the club paid the facility and supplied an exemption certificate. Members' own meals remained taxable.
Were architectural services performed by an employee for the employer taxable under Connecticut Ruling 89-31?
No. Employee services for the employer were not subject to sales and use taxes even when the work was architectural, and the employee did not have to file Form REG-1 for those services. The ruling is …
Did nonprofit status alone qualify an association's periodicals and writings for Texas's publication exemption?
No. The association was nonprofit but did not fall within the religious, philanthropic, charitable, historical, scientific, or similar organizations covered by the legislation.
Is an electronic voice-messaging and telephone-answering service taxable as a telephone or telegraph service?
Yes — an all-electronic voice-messaging and answering service is a taxable telephone or telegraph service under Tax Law § 1105(b), except for interstate and international messages. Tigon Corporation l…
Did moving equipment become taxable fabrication when the mover had to disassemble and reassemble it?
No. Reassembly performed as part of the move was not taxable refabrication, so the moving service remained nontaxable when the equipment was not remodeled, repaired, or cleaned.
Which location determined the local tax on a paging service's telecommunications transmission?
The point where the paging provider began its own transmission. Local tax was due based on the location where it received the incoming call and transmitted the paging signal.
Did workers' compensation premiums included in a roofer's lump-sum contract enter the taxable sales price?
It depended on the job. Residential lump-sum roofing was not taxed to the customer, but the entire nonresidential contract was taxable, including the embedded premiums.
Are the fees and dues a real-estate multiple listing service charges its member brokers subject to sales tax?
Yes. All of the listing service's charges — including the one-time initiation fee and the annual dues — are receipts from a taxable information service. Mohawk Valley Listing Service, Inc. is a New Yo…
Was a restaurant-delivery service's separate delivery charge taxable when it did not sell the food?
No, under the stated facts. The service acted as a third-party carrier, collected only exact reimbursement for the meal, and did not sell the food.
Is a design change to a printing press taxable, and does it matter whether the change happens before or after the press is delivered to the customer?
It depends on timing: a design change made before the press is delivered is exempt, but one made after delivery is a taxable repair subject to local (but not state) tax. William R. Barlow sells printi…
Are the charges for confidential product-testing reports about a company's own products a taxable information service?
No — confidential reports about only the customer's own products are an exempt personal and individual information service. Garden Way Incorporated, a maker of lawn and garden equipment, hired a Flori…
Is a country club member's voluntary contribution to a clubhouse renovation subject to the sales tax on club dues?
No — a truly voluntary contribution is not taxable dues, even though mandatory assessments for the same project would be. Joseph W. Burns, a Senior member of the Wykagyl Country Club, asked whether hi…
Were flood-claim adjustment services sold to private insurers taxable, and who owed the tax if the insurer refused to pay it?
Yes under the 1989 letter. Federal reimbursement did not exempt services sold to private insurers, and the adjuster remained responsible for collecting and remitting the tax.
How did Texas calculate tax on an equipment financing lease and its early-settlement payment?
Tax applied to the lease contract's taxable value, including the required purchase option and early-termination penalty, less the settlement rebate—not merely the equipment's original cost.
Was spraying homeowners' pecan trees taxable when some owners sold the harvested nuts?
Yes. All four spraying jobs were taxable structural pest-control services, including the jobs involving commercially used pecans.
Did an interstate motor carrier create South Carolina corporate income-tax nexus by regularly hauling freight into and across the state without a South Carolina terminal?
Yes. The carrier's regular and continuous use of South Carolina highways to haul freight, together with its state Class F operating license, established substantial nexus. South Carolina could tax the…
A small company provides both a telephone answering service and a telex/fax relay service — does owning no transmission equipment of its own keep it out of New York's Article 9 telegraph/telephone tax, or does the telex/fax activity still count as a taxable transmission business?
A telex/fax service is taxable under Article 9 as a telegraph/telephone business regardless of whether the company owns any transmission equipment or lines, while a telephone answering service is an A…
Was packaged horchata exempt as a food product because it could be used in place of milk?
No. The submitted literature described the non-dairy rice drink as a soft drink, so the Comptroller treated it as taxable rather than an exempt food product.
When were installed warehouse racks treated as new construction rather than taxable tangible personal property?
Only rack-supported systems built as part of a new warehouse were treated as new construction. Other rack systems remained tangible personal property, making the total installed charge taxable.
Are the amounts a country club pays a management company for workers who maintain its grounds subject to sales tax, when the club hires and supervises the workers but the management company runs the payroll?
They are taxable. Skyline Golf and Country Club, Inc. paid a management company for workers who maintain and service its grounds; the club hired, scheduled, supervised, and could fire the workers, but…
Does a freelance photographer have to charge sales tax on separately billed reimbursable expenses like travel, film, and lodging?
Yes — separately billed reimbursable expenses are part of the taxable charge for the photographs. Peter Vadnai, a freelance photographer, billed clients separately for expenses (food and lodging, airf…
Are advertising envelopes used to mail promotional material out of state from a New York post office exempt from sales and use tax?
It depends on the date: taxable for mailings before September 1, 1989, and exempt for out-of-state mailings on or after that date. Garden Way Incorporated used 'promotional covers' — envelopes heavily…
How these rulings are useful
- See how the rule applies: A letter ruling shows how a state revenue department actually applied the tax law to a specific business and set of facts.
- Plan with confidence: Find a ruling with facts close to yours before you charge, remit, or claim an exemption.
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