This Ruling has been obsoleted by AN 94(4)
The Department considers your client to be involved in a renovation project solely within the structure of an existing building.
The fact that the building is vacant prior to the start of the renovation project is immaterial to the application of the sales tax. Likewise, the fact that there is a high construction cost for the renovation work in relation to the purchase price of the building does not permit renovation work to be categorized as new construction. Finally, with respect to the policy considerations set forth in your request, our agency is not the proper forum for the resolution of these issues.
Based on the foregoing, it is ruled that the services rendered by a general contractor and its subcontractors to convert a vacant manufacturing building to residential condominiums constitutes a taxable sale under Connecticut General Statute Sections 12-407(2)(i)(I).
March 7, 1990