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BTLG Table of Contents > Sales and Use Tax Annotations > I > 325.0000 Interstate and Foreign Commerce > Annotation 325.1420

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I

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325.0000 Interstate and Foreign Commerce—Regulation 1620

Annotation 325.1420

(c) Shipments from California to Points Outside State

(5) Exports

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325.1420 "Stream of Commerce." The test to be applied to a transaction alleged to be an export sale is whether or not at the time of sale the property involved was sufficiently "within the stream of foreign commerce" so as to partake of the Constitutional exemption.

Where several vessels are sold and delivered to a foreign government at a point in California and thereafter towed to another point in California for refitting, the sale has been completed in California and the vessels have not entered "within the stream of foreign commerce," and the sales tax applies. 5/26/53.