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BTLG Table of Contents > Transactions and Use Tax Annotations > 800.0000 Application of Transactions (Sales) Tax and Use Tax > Annotation 800.1000

Transactions and Use Tax Annotations

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800.0000 Application of Transactions (Sales) Tax and Use Tax—Regulation 1823

Annotation 800.1000

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800.1000 Subcontractors Located in Other Countries. A taxpayer's principal place of business is located in Sacramento County. He contracts out most activities such as order taking, warehouse storage, fulfillment, order processing, and shipping to subcontractors located in other counties. Shipments are made by UPS, Federal Express, or other common carriers. Sources of customers are ads which are placed in various publications which contain "800" numbers. Orders received are relayed to a warehouse (outside of Sacramento) for shipment.

Taxpayer's subcontractor's operations qualify as "engaged in business" in each taxing district where they are located. Accordingly, taxpayer is liable for collection of the district tax for sales to customers located in a district where taxpayer is "engaged in business". The purchaser is responsible for reporting the use tax in locations where taxpayer is not "engaged in business". 6/25/93.