Ruling 89-272

Tangible Property  

This Ruling has been superseded by PS 92(13)

Your client, the corporation, performs an operation whereby it records and mixes music that is transferred to tape. The corporation subsequently sends the tape to New York to a master house where the music is remixed and then mastered.

The service rendered by the corporation that involves conducting recording sessions, mixing the music from the recording session and transferring it to tape is not taxable. However, if the corporation sells tapes without performing said service, the sales tax applies to the total sales price unless passage of title to the tape occurs outside Connecticut.

LEGAL DIVISION

December 12, 1989