Connecticut — Sales & Use Tax

Connecticut imposes sales and use tax under Chapter 219 of the Connecticut General Statutes on the gross receipts from three categories of transactions: (1) retail sales of tangible personal property, (2) rental or leasing of tangible personal property, and (3) rendering of certain enumerated services. The tax is imposed on retailers making sales at retail in Connecticut for consideration. The standard rate is 6.35%, though higher rates apply to specific categories including luxury items, motor vehicles over $50,000, meals, and room occupancy. Connecticut does not permit local jurisdictions to impose additional sales taxes.

Source: Conn. Gen. Stat. Chapter 219; CT DOR Sales Tax Information

Connecticut requires remote sellers to register and collect sales tax if they exceed both of the following thresholds during the preceding 12-month period ending September 30: (1) gross receipts of at least $100,000 from retail sales into Connecticut, and (2) 200 or more separate retail transactions. Both thresholds must be met; exceeding only one does not trigger nexus. Sellers meeting both thresholds must register and begin collecting tax on October 1 of the following year. This requirement took effect July 1, 2019 and is codified in the current version of Conn. Gen. Stat. § 12-407 as amended by Public Act 19-117, reflected in Chapter 219 of the General Statutes. No material law or threshold change has occurred since the last update.

Source: Conn. Gen. Stat. Chapter 219 § 12-407

Connecticut imposes a 6.35% sales tax on retail sales of tangible personal property and the rendering of taxable services. This rate applies uniformly statewide; Connecticut does not authorize local jurisdictions to impose additional sales taxes. Certain categories of transactions are subject to different rates under the same statute.

Source: Conn. Gen. Stat. § 12-408

Connecticut taxes only those services specifically enumerated in statute; services are presumed exempt unless expressly listed. This contrasts with tangible personal property, which is presumed taxable unless exempted. Conn. Gen. Stat. § 12-407(a)(2) defines "sale" to include the rendering of enumerated services detailed in subsection (a)(37), including computer and data processing services, telecommunications services, real property maintenance and repair services, repair and maintenance of tangible personal property, storage services, spa and salon services, interior design, veterinary services, pet grooming, and armored car services, among others. The Department of Revenue Services maintains a comprehensive list of taxable services based on the statutory enumeration. Practitioners must verify whether a specific service appears on the statutory list; general categories or similarity to listed services do not establish taxability.

Source: Conn. Gen. Stat. § 12-407; CT DOR Services Subject to Sales and Use Taxes

Connecticut requires marketplace facilitators to collect and remit sales tax on sales they facilitate for marketplace sellers, effective December 1, 2018. A marketplace facilitator is deemed the retailer of each facilitated sale and assumes all collection, remittance, and recordkeeping obligations as if it were the seller. A facilitator is any person who (1) facilitates at least $250,000 in retail sales by marketplace sellers during the prior 12-month period by providing a forum listing tangible personal property or taxable services, (2) collects payment from customers and remits to sellers, and (3) receives compensation for these services. Marketplace sellers are relieved of collection duty if the facilitator provides a written certificate (Form DRS-055) certifying registration and collection responsibility, or has a contract explicitly requiring the facilitator to collect tax on all facilitated sales.

Source: Conn. Gen. Stat. § 12-408e; CT DOR Policy Statement 2018(7), OCG-8

Connecticut requires every person who intends to engage in business as a retailer of tangible personal property or taxable services to obtain a Sales and Use Tax Permit from the Department of Revenue Services before commencing operations. The registration requirement applies to all business entities — individuals, corporations, partnerships, and other organizations — regardless of the number of sales made or the amount of tax collected. Manufacturers and wholesalers must register in addition to retailers. All building contractors, including subcontractors, must obtain a permit prior to providing any services in Connecticut, even if the services are not taxable or the client is tax-exempt.

The DOR charges a non-refundable $100 registration fee for each initial Sales and Use Tax Permit. Businesses operating multiple physical locations must obtain a separate permit for each location; each location-specific permit requires its own display. Connecticut law does not provide an exception to the registration requirement for casual or isolated sales — defined as infrequent sales of a nonrecurring nature made by persons not engaged in the business of selling tangible personal property or taxable services.

Remote sellers who exceed both economic-nexus thresholds ($100,000 in gross receipts from retail sales into Connecticut and 200 or more separate retail transactions during the preceding 12-month period ending September 30) are required to register. Both thresholds must be met; exceeding only one does not trigger the registration obligation. Sellers meeting both thresholds must register and begin collecting tax on October 1 of the following year. Marketplace facilitators with $250,000 or more in facilitated retail sales during the prior 12-month period must also register and assume collection responsibility for sales they facilitate.

Permit display requirement

Connecticut General Statutes § 12-409(d) requires every permit holder to display the Sales and Use Tax Permit conspicuously at the business location for which it was issued. Customers must be able to see it. For temporary sales events — flea markets, craft shows, trade shows, antique shows, or fairs — sellers must display the permit prominently at their booth or table. Failure to display the permit can result in a ten-day written notice for non-compliance and a hearing; if the permit holder cannot demonstrate reasonable cause, the Department may suspend or revoke the permit under Conn. Gen. Stat. § 12-409(f).

Penalties for operating without a permit

Under Conn. Gen. Stat. § 12-409(h), operating without a valid Sales and Use Tax Permit triggers automatic civil penalties: $250 for the first day a person engages in business without the required permit, and $100 for each subsequent day. The penalty may be waived only if the person proves that the failure to obtain or renew the permit was due to reasonable cause and was not intentional or due to neglect. Willful failure to obtain a permit — when the person is already aware of the obligation — is a criminal offense punishable by a fine of not more than $500, imprisonment of not more than three months, or both, for each offense.

Non-transferability and change-of-ownership rules

Sales and Use Tax Permits are not transferable. If a purchaser acquires an existing business, the purchaser may not use the permit issued to the previous owner and must obtain a new permit in the purchaser's own name. Similarly, if the ownership structure of a business changes — for example, a sole proprietorship becomes a partnership or corporation — a new permit is required.

Source: CT DOR Sales and Use Tax Information; Conn. Gen. Stat. Chapter 219

Connecticut imposes an effective 7.35% sales and use tax on meals sold by eating establishments, caterers, and grocery stores. This rate consists of the standard 6.35% base sales tax rate plus an additional 1% surcharge specifically imposed on meals and certain beverages. The statute defines "meals" by reference to Conn. Gen. Stat. § 12-412(13) and the implementing regulation at Conn. Agencies Regs. § 12-426-29, which describe meals as food products furnished, prepared, or served in such form and portions that they are ready for immediate consumption, including take-out and to-go sales.

What constitutes a meal

Under Conn. Agencies Regs. § 12-426-29, "meals" means food products for human consumption sold in such form and portions that they are ready for immediate consumption and are of a type normally consumed on or near the location of the seller. The definition expressly includes items sold on a take-out basis. The regulation clarifies that meals do not include bulk sales of food products unless meant for consumption on or near the seller's location; examples of bulk sales that are not meals include ice cream in half-gallon containers, whole pies, cold sliced meat sold by the pound, and cold salads sold by the pound. Conversely, whole pizza pies and buckets of fried chicken are treated as meals because they are not bulk sales under the regulatory framework.

Covered beverages

The additional 1% surcharge also applies to spirituous, malt, or vinous liquors; soft drinks, sodas, and beverages ordinarily dispensed at bars and soda fountains; and beverages sold in connection with meals. This brings the effective tax rate on these beverages to 7.35% when sold by an eating establishment, caterer, or grocery store as part of a meal transaction.

Who must collect the 7.35% rate

The statute imposes the 7.35% effective rate on sales by three categories of sellers:

• Eating establishments: Conn. Agencies Regs. § 12-426-29(2) defines an eating establishment to include restaurants, cafeterias, coffee and donut shops, fast food restaurants, ice cream shops, pizzerias, mobile food trucks or carts, refreshment stands, sandwich shops, snack bars, and vending machines.

• Caterers: Conn. Agencies Regs. § 12-426-29(3) defines a caterer as a person engaged in the business of preparing meals and either serving them on premises designated by the customer, or delivering (but not serving) meals to premises designated by the customer.

• Grocery stores: Effective October 1, 2019, the 7.35% meals tax applies uniformly to meals sold at grocery stores. Prior to that date, grocery stores taxed meals under different rules. CT DOR Policy Statement 2019(5) clarified that sandwiches, grinders, coffee, or tea prepared in a supermarket (including at a delicatessen counter) for takeout are taxable at 7.35%, as are meals sold in areas of a supermarket where food is intended to be consumed on-site, such as snack bars or food courts—even if the purchaser takes the meal off premises.

Effective date and statutory history

The 1% additional tax on meals was enacted by 2019 Conn. Pub. Acts 117, §§ 323–324, and became effective October 1, 2019, applicable to sales occurring on or after that date. Before October 1, 2019, meals were subject to the standard 6.35% rate. The authorizing statutes are Conn. Gen. Stat. § 12-408(1)(I) for sales tax and Conn. Gen. Stat. § 12-411(1)(I) for use tax; both provisions impose the additional 1% "with respect to the sale [or acceptance or receipt] of meals … sold by an eating establishment, caterer or grocery store" and the enumerated beverages "in addition to the tax imposed under subparagraph (A)."

Application to dine-in, takeout, and delivery

The 7.35% rate applies uniformly to meals whether consumed on the seller's premises, taken off-site, or delivered. The regulation expressly includes take-out sales in the definition of "meals," and CT DOR Policy Statement 2019(5) confirms that delivery services that purchase meals from restaurants for resale and delivery to customers must charge sales tax on the charges for the meals, including the delivery fee, in the taxable gross receipts. The readiness for immediate consumption—not the location of consumption—determines whether an item is a meal subject to the 7.35% rate.

Cross-reference: exemptions

Certain sales of meals remain exempt even though the general 7.35% rate applies to most meal sales. Conn. Gen. Stat. § 12-412(9) exempts sales of meals, candy, confectionery, and beverages (except alcoholic beverages) in educational institutions to members of those institutions, including sales using prepaid meal plan cards. Conn. Gen. Stat. § 12-412(27) exempts meals sold through coin-operated vending machines or at unattended honor boxes (though candy, confectionery, and soda sold through such machines remain taxable unless priced at 50 cents or less). Additional exemptions exist for meals sold by nonprofit organizations under specified conditions (Conn. Gen. Stat. § 12-412(94)) and for meals made to exempt charitable or governmental entities meeting all the requirements in Conn. Agencies Regs. § 12-426-29(c)(3).

Source: Conn. Gen. Stat. § 12-408; Conn. Gen. Stat. § 12-411; 2019 Conn. Pub. Acts 117, §§ 323–324; Conn. Agencies Regs. § 12-426-29; CT DOR Policy Statement 2019(5).pdf)

Connecticut imposes a 7.75% sales and use tax rate on sales of luxury goods—a higher rate than the standard 6.35% base rate. This rate applies to three categories of high-value items, determined by sales-price thresholds. The luxury rate is imposed on the entire sales price of the item, not merely on the amount exceeding the threshold.

Motor vehicles exceeding $50,000

Connecticut taxes motor vehicles with a sales price exceeding $50,000 at 7.75% on the entire sales price. For purposes of this threshold, "motor vehicle" has the meaning provided in Conn. Gen. Stat. § 14-1, but excludes: (1) motor vehicles subject to the reduced 4.5% rate for nonresident military personnel stationed in Connecticut under Conn. Gen. Stat. § 12-408(1)(C); (2) motor vehicles with a gross vehicle weight rating (GVWR) over 12,500 pounds; and (3) motor vehicles with a GVWR of 12,500 pounds or less that are not used for private passenger purposes but are instead designed or used to transport merchandise, freight, or persons in connection with any business enterprise and issued a commercial registration or more specific type of registration by the Department of Motor Vehicles.

A motor vehicle priced at $55,000 is taxed at 7.75% on the full $55,000, not at the standard 6.35% rate on the first $50,000 and 7.75% only on the $5,000 increment. The same threshold-crossing rule applies to jewelry and clothing/accessories.

Jewelry exceeding $5,000

Jewelry—whether real or imitation—with a sales price exceeding $5,000 is taxed at 7.75% on the entire sales price. The statute does not distinguish between precious-metal jewelry, costume jewelry, or other forms; the category "jewelry, whether real or imitation" is defined solely by sales price. A piece of jewelry priced at $6,000 is taxed at 7.75% on the full $6,000.

Clothing, footwear, and accessories exceeding $1,000

Connecticut imposes the 7.75% luxury rate on the following items when the sales price exceeds $1,000 per item:

• Articles of clothing or footwear intended to be worn on or about the human body
• Handbags
• Luggage
• Umbrellas
• Wallets
• Watches

Each of these items is evaluated individually; the $1,000 threshold applies per item, not per transaction. An item of clothing priced at $1,200 is taxed at 7.75% on the entire $1,200. The luxury rate does not apply to special clothing or footwear primarily designed for athletic activity or protective use that is not normally worn except when used for the athletic activity or protective use for which it was designed; such items remain subject to the 6.35% standard rate (or may be exempt under separate provisions). This exclusion is codified at Conn. Gen. Stat. § 12-407(a)(2)(S) and applies to the definition of "articles of clothing or footwear" throughout the sales tax statutes.

Interaction with the clothing exemption and sales tax holiday

Connecticut exempts clothing and footwear under $50 per item from sales tax year-round under Conn. Gen. Stat. § 12-412(77). Items priced at $50 or above but not exceeding $1,000 are taxable at the standard 6.35% rate. Items priced above $1,000 are taxable at the 7.75% luxury rate. During the annual sales tax holiday (the third Sunday through the following Saturday in August each year under Conn. Gen. Stat. § 12-407e), the exemption threshold for clothing and footwear rises to $100 per item, but items priced at $100 or more remain taxable at their applicable rates (6.35% for items $100 to $1,000, and 7.75% for items over $1,000).

Sales tax vs. use tax; effective dates

The 7.75% luxury rate applies to both sales tax under Conn. Gen. Stat. § 12-408(1)(H) and use tax under Conn. Gen. Stat. § 12-411(1)(H). The luxury tax on jewelry and clothing was enacted in 2011; the luxury tax on motor vehicles over $50,000 was also enacted in 2011. The current rate of 7.75% has been in effect since July 1, 2011 (increased from 7% under 2011 Conn. Pub. Acts 6, effective July 1, 2011, applicable to sales occurring on or after that date).

Source: Conn. Gen. Stat. § 12-408; Conn. Gen. Stat. § 12-411; Conn. Gen. Stat. § 12-407(a)(2)(S); Conn. Gen. Stat. § 12-412(77); Conn. Gen. Stat. § 12-407e

Connecticut law does not provide any statutory or regulatory mechanism for waiving, suspending, or modifying the economic nexus thresholds that trigger sales tax collection and registration obligations for remote sellers. Under Conn. Gen. Stat. § 12-407(a)(15)(A) as amended by Public Act 19-117, a remote seller must register and collect Connecticut sales tax if, during the twelve-month period ending September 30, the seller both (1) makes at least $100,000 in gross receipts from retail sales into Connecticut and (2) conducts 200 or more separate retail transactions into the state.

No language in Chapter 219 of the Connecticut General Statutes or in regulations issued by the Department of Revenue Services provides for temporary waivers or modifications of these nexus thresholds—whether due to emergency situations (such as a disaster), temporary spikes in sales, remote facilitation activity, or marketplace-only transactions. DRS bulletins and formal policy statements likewise contain no reference to discretionary relief or waiver authority concerning economic nexus standards for remote sellers.

This rule holds true even in circumstances involving disaster relief sales, short-term surges (such as those caused by market volatility or product launches), or where a seller's only Connecticut transactions are conducted through a registered marketplace facilitator. Remote sellers should assume the $100,000 and 200-transaction nexus tests apply as written, with no exceptions for special circumstances unless expressly amended by statute or regulations in the future.

Source: Conn. Gen. Stat. § 12-407; CT DRS Sales and Use Tax Information

Connecticut law imposes a collection and remittance duty on marketplace facilitators for sales they facilitate on behalf of third-party sellers. However, there is a single specific statutory exception: as of July 1, 2023, marketplace facilitators are not required to collect and remit Connecticut sales tax on rentals of passenger motor vehicles or rental trucks when those rentals are made on behalf of a rental company. Instead, the rental company itself remains the party responsible for sales tax collection and remittance on such transactions.

Scope and effective date

The exception was enacted via Public Act 22-118 (2022) and codified in Conn. Gen. Stat. § 12-408e(b)(2). It became effective July 1, 2023. The law’s language provides that "a marketplace facilitator shall not be considered a retailer with respect to any sale facilitating the rental of a passenger motor vehicle or rental truck, as defined in section 12-692, on behalf of a rental company, as defined in section 12-692."

Limitation—only exception in statute

No other exceptions, thresholds, carve-outs, or waivers are established in the current law or Department of Revenue Services published guidance. Other than this single type of vehicle rental, marketplace facilitators must collect and remit Connecticut sales and use taxes on all taxable sales made through their platform if they meet the statutory sales thresholds. The statutory definition does not grant discretion to DRS to create additional exceptions administratively, nor are there relief provisions for certain sellers, products, or sales volumes outside the context of rental vehicle facilitation.

Source: Conn. Gen. Stat. § 12-408e(b)(2); 2022 Conn. Pub. Acts 22-118, § 340; OLR Summary, P.A. 22-118, p. 61

Connecticut practitioners frequently encounter boundary questions over whether a service fits within a taxable enumerated category—particularly the "computer and data processing services" category under Conn. Gen. Stat. § 12-407(a)(37)(A) and the "services to real property" category under § 12-407(a)(37)(I). The Department of Revenue Services (DRS) and Connecticut courts have developed nuanced guidance, refining statutory tests through rulings and case law.

Computer and Data Processing Services (§ 12-407(a)(37)(A))

• Ruling No. 2010-2 (issued 2010): DRS determined that remote access to software (SaaS/cloud products) is not taxable as "computer and data processing services" when the purchaser does not receive a copy of the software for use in Connecticut and only accesses the provider’s server via the internet. The ruling emphasizes actual possession and control in Connecticut as the statutory test; transfer of a license or downloaded customer software may trigger tax. The DRS further noted that the taxable status of processing, manipulating, or inputting data depends on whether the dominant purpose is the provision of processing (taxable) versus provision of information or reports (potentially not taxable). [See: DRS Ruling No. 2010-2, pp. 2–3.]
• Ruling No. 94-6 (issued 1994): DRS analyzed a service involving both data processing (electronic compile, manipulation, and report generation) and transmission of results to customers. The DRS ruled the entire charge was subject to sales tax, finding that classification turns on the “essential character” of the transaction; where a single charge combines taxable computer processing and nontaxable information/reporting, the dominant purpose test applies unless charges are separately stated. "Purely clerical" or manual data entry, however, is not subject to tax. [See: DRS Ruling No. 94-6, factual background and analysis.]

Services to Real Property (§ 12-407(a)(37)(I))

• Waterbury v. Washington Nat’l Ins. Co., 214 Conn. 464 (1990): The Connecticut Supreme Court interpreted "services to real property" to mean only those activities that physically maintain or improve property—e.g., cleaning, repair, landscape work—and not management, consulting, or administrative services. The facts involved janitorial contracts and facilities management; the Court distinguished taxable hands-on services from nontaxable managerial oversight. The holding grounds the statutory test in a physical-improvement distinction. [See: Waterbury, 214 Conn. at 472–476.]
• DRS Policy Statement 2006(3): Administrative guidance here itemizes taxable services (e.g., snow removal, landscaping, painting, pest control, HVAC, electrical/telecom wiring, window washing). Examples of nontaxable services include architectural design and project management when these do not involve direct physical alteration or repair work. The Policy Statement calls for a fact-based assessment: contracts involving both taxable and nontaxable work must segregate charges, or tax applies to the entire lump sum. [See: DRS Policy Statement 2006(3), Section IV.]

Methodology and Dominant Purpose Rule

• DRS rulings emphasize either (1) segregating charges if possible (tax applies only to the taxable portion) or (2) using the dominant purpose or essential character of the service if the charges are not separable. Practitioners must parse both the statutory category and the specific mechanics and contractual allocation in each scenario, referencing the details in DRS guidance and rulings for support.

Source: Conn. Gen. Stat. § 12-407(a)(37) Source: DRS Ruling No. 2010-2 Source: DRS Ruling No. 94-6 Source: DRS Policy Statement 2006(3) Source: Waterbury v. Washington Nat’l Ins. Co., 214 Conn. 464 (1990)

Not yet human confirmed.

Connecticut imposes a 7.75% sales and use tax rate on sales of luxury items, including motor vehicles priced over $50,000, jewelry over $5,000, and specific articles of clothing, footwear, and accessories priced over $1,000 per item. Practitioners selling both standard and luxury-rate goods must ensure proper collection and remittance of the higher rate where applicable. However, Connecticut law and official Department of Revenue Services (DRS) guidance do not require sellers to separately identify or itemize luxury-rate sales on customer invoices beyond general best practices of itemizing taxable items and their applicable tax rates.

No express invoice-statement rule

Conn. Gen. Stat. § 12-408 specifies the imposition and rate structure but does not mandate a separate invoice line or notation for luxury tax items. DRS forms and online guidance do not set out customer-facing invoicing requirements specific to the luxury rate. Connecticut Form OS‑114 (Sales and Use Tax Return) provides a dedicated column for luxury goods sales at 7.75%, indicating that sellers must track, account for, and report these items distinctly when remitting tax, but the reporting requirement applies to the tax return, not to the invoice shown to the customer.

Accounting and internal controls

While the statutes and DRS do not dictate invoice format, sellers are responsible for properly programming point-of-sale and accounting systems to apply the 7.75% rate to qualifying items and to segregate those sales in their own records to enable accurate filing. The primary regulatory focus is on remitting the correct tax for each category—as shown on OS‑114—rather than on how sales are visually presented to the customer.

Audit considerations

No administrative ruling, policy statement, or audit bulletin from DRS prescribes luxury-items-specific invoicing or recordkeeping beyond the tax return’s categorical reporting. However, businesses should expect DRS auditors to request underlying documentation (like invoices, itemized receipts, or register detail reports) to verify that the proper tax rate was charged and remitted for each transaction. Failure to apply the correct rate or keep adequate documentation could result in an assessment.

No known DRS publications or FAQs address separate statement or labeling on invoices. As of June 2026, no specific Connecticut regulatory or administrative requirement exists for luxury sales itemization beyond those applicable to all taxable sales.

Source: Conn. Gen. Stat. § 12-408 Source: CT DRS Sales and Use Tax Return (Form OS‑114) Source: CT DRS Special Notice 2011(10)

Connecticut’s sales tax treatment of drop shipments—where an out-of-state retailer sells to a Connecticut customer but instructs a third-party supplier (often a wholesaler or manufacturer) to ship goods directly to the Connecticut address—is governed by statute and official DRS guidance.

Who must collect the tax? Under Conn. Gen. Stat. § 12-407(a)(3)(A) and as set out in DRS Policy Statement 2013(3), the Connecticut-registered supplier (the drop shipper) is considered the retailer for sales tax purposes in these transactions, even if the out-of-state seller is not registered with Connecticut. The supplier is responsible for collecting Connecticut sales tax unless the customer provides proper exemption documentation. If the supplier knows the retail sales price, it must collect tax on that amount; if not, tax is calculated on its own sales price to the retailer.

Resale certificate requirements The key point in Connecticut is that a resale or exemption certificate from an unregistered retailer (the middle party) does not relieve the Connecticut supplier of its duty to collect the tax. Only a Connecticut resale certificate, the Multistate Tax Commission Uniform Sales & Use Tax Certificate (for resale transactions), another DRS-approved exemption certificate, or a direct payment permit provided by the Connecticut customer satisfies exemption requirements. If the customer is not purchasing for resale and does not provide valid documentation, the supplier is required to collect and remit sales tax. (DRS PS 2013(3), "In a drop shipment situation the burden rests with the Connecticut supplier to collect tax unless it obtains an acceptable certificate.")

Multi-tier drop-shipments and gaps Connecticut DRS has not issued guidance specifically addressing multi-tier drop shipment scenarios that involve more than one out-of-state intermediary before reaching the Connecticut customer. PS 2013(3) and DRS Ruling 2003-2 do not discuss chains beyond the classic three-party model of out-of-state seller, Connecticut supplier, and in-state customer. As of June 2026, there is no published administrative authority on whether exemption certificates from non-customer intermediaries in these more complex structures are honored in Connecticut—leaving this an open question for advisory or future DRS clarification.

Fulfillment house exclusion The DRS has ruled (Ruling 2003-2) that the fulfillment house exclusion does not apply in drop shipment cases: when a Connecticut supplier ships goods at the direction of an unregistered retailer to a Connecticut customer, the supplier remains liable for tax unless it receives the appropriate documentation from the customer.

Source: Conn. Gen. Stat. § 12-407(a)(3)(A) Source: DRS Policy Statement 2013(3) Source: DRS Ruling 2003-2

Not yet human confirmed. As of 2026-06-22, the treatment of multi-tier chains beyond the three-party structure remains unaddressed in Connecticut DRS guidance.