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Business Taxes Law Guide—Revision 2024
Sales and Use Tax Annotations
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395.0000 Occasional Sales—Sale of a Business—Business Reorganization—Regulation 1595
Annotation 395.1680
(h) Ownership "Substantially Similar"—"Real or Ultimate" Ownership
395.1680 Single Sale to Several Entities. Where a taxpayer transfers substantially all of its assets in a single transaction to several entities with the result that its real or ultimate ownership of the property in one or more of the transferee entities is changed more than 20 percent, the transaction is not exempt as an occasional sale pursuant to section 6006.5(b). For such a transaction to be exempt thereunder, the taxpayer's ownership of the property in each of the transferee entities must not be changed more than 20 percent. 3/18/69.