Ruling 89-5

Capital Gains, Dividends and Interest Tax

This Ruling has been obsoleted by AN 94(2)

The distribution paid to shareholders of the Treasury Trust Portfolio would be subject to the dividends tax, where those shareholders are natural persons who are residents of Connecticut. The fact that the distributions are derived from direct U.S. Government obligations and from repurchase agreements collateralized by U.S. Government obligations is not pertinent, because the shareholders are not the owners of such obligations.

LEGAL DIVISION

April 3, 1989