You have further requested a ruling as to whether the subject services are related to media advertising. Further you have requested a ruling as to when and under what circumstances the above services, if taxable, would be subject to Connecticut sales and use tax. Facts Taxpayer is a Connecticut corporation which provides direct mail advertising services. It has a license agreement with a Florida corporation providing an assignment of certain territory for advertising purposes. Taxpayer solicits businesses in the assigned territory to advertise the businesses' products or services via a collective direct mailing of brochures, coupons, flyers and similar advertising material to households.
Taxpayer assists the businesses in the preparation of advertising material.
Taxpayer obtains a copyright on the advertising material it helps prepare. After agreement of the content of the advertising material the Florida corporation prepares the material. After customer approval, the advertising material is printed by the Florida corporation. The material is sorted, placed in envelopes and mailed from Florida to Connecticut households. Taxpayer bills its customers on the material mailed to designated households.