Ruling 89-151


This Ruling has been obsoleted in part by AN 94(4)

You have asked the Legal Division several questions as to whether your services as a freelance writer are subject to the sales and use tax under Public Act No. 89-251, which amended the language of Conn. Gen. Stat. §12-407(2)(i)(J) to tax "business analysis, management, consulting and public relations services," or under Conn. Gen. Stat. §12-407(2)(i)(W) as "advertising or public relations services."

Because the Department has defined "consulting" to mean the providing of advice on matters relating to the operations of a client's business, it is our opinion that the work of a freelance writer is not considered to be "consulting" within the scope of this definition.

The creation of a freelance article without further involvement in its placement in a publication or in its dissemination service to the public is not considered to be a public relations service by the Department.

The Department has previously taken the position that a freelance article is not tangible personal property subject to the sales tax.

Therefore, a service that involves solely the creation of a freelance article has no sales tax consequences under our current law. Thus, your services to X Corporation are not subject to the sales tax either when rendered to the worldwide headquarters office of X Corporation in Hartford, Connecticut or to its major operating group in New York.


October 20, 1989