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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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325.0000 Interstate and Foreign Commerce—Regulation 1620

Annotation 325.1145

(c) Shipments from California to Points Outside State

(5) Exports

325.1145 Delivery in State for Subsequent Export. The delivery in this state of a mold to a foreign purchaser who then shipped it out of the country was a taxable sale even though the mold was never used in this state or country. The seller did not "irrevocably commit the property into the process of exportation." (Regulation 1620(a)(3)(C)(1).)

Had the mold been used in the production of parts before it was sold to the customer, tax would have been due on cost of the mold as well as on the subsequent sale in this state. 5/18/90.