This Ruling has been obsoleted in part by AN 2000(8)
Forestry Management Services
According to the information presented in your letter, forestry management services involve an inventory of all trees by type on the land. A plan is prepared and submitted to the land owner containing recommendations for tree care, harvesting and planting. When the plan is approved by the land owner, an implementation phase is performed whereby trees are selected for harvest and removed from the land. The forestry manager makes an arrangement for the sale of the timber and receives a commission based on a percentage of the proceeds for his forestry management services.
Land planning services involve studying the most efficient use of the land and providing recommendations to assist in the subdivision of land. Soil testing services are also rendered by your client.
The total gross receipts for forestry management services are taxable as landscaping services pursuant to §12-407(2)(i)(X) of the Connecticut General Statutes, as amended by Public Act No. 89-251. Broker fees for arranging the sale of the timber are taxable pursuant to §12-407(2)(i)(U) of the Connecticut General Statutes, as amended by Public Act No. 89-251. Soil testing services are exempt from sales and use tax. Land planning services are not subject to sales and use tax.
September 26, 1989