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Business Taxes Law Guide—Revision 2024

Sales and Use Tax Annotations


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I


325.0000 Interstate and Foreign Commerce—Regulation 1620

Annotation 325.1396

(c) Shipments from California to Points Outside State

(5) Exports

325.1396 Shipping Containers Sold for Export. A taxpayer sells shipping containers to a Canadian company. The customer takes delivery of the containers in California and then transports them outside California for loading of property for export. The sale of the containers do not qualify for the export exemption because the purchaser took possession of the containers prior to commitment of the containers into the process of exportation. Also, the sale does not qualify for the interstate commerce exemption since the purchaser took possession of the containers in California. Therefore, the sale of the containers is subject to sales tax. 06/27/96.