Ruling 91-8

Nonprofit Charitable Hospitals

This Ruling has been obsoleted by AN 94(4)

FACTS:

X is a nonprofit, charitable hospital. The Internal Revenue Service has determined that X qualifies as a charitable organization under Section 501(c)(3) of the Internal Revenue Code. X also holds a State of Connecticut sales and use tax exemption permit.

X has formed a Division to provide human relations and organizational consulting services to public and private companies as well as non-profit organizations.

The efforts of the Division are all directed to topics allied with X's mental health objectives such as stress management in the work place, corporate "wellness" and, in general, the human relations side of operations that bear upon the quality of a work environment from the mental health perspective, including personal problems involving morale, motivation, collaboration and communication.

ISSUE:

Whether services rendered by Division are subject to sales and use taxes under Section 12-407(2)(i) of the Connecticut General Statutes.

RULING:

The services rendered by the Division do not come within the taxable services enumerated in Section 12-407(2)(i) of the Connecticut General Statutes and, as a result, are not subject to sales and use taxes.

LEGAL DIVISION

April 2, 1991